https://www.taxtmi.com/caselaws?id=285594 A reference under Section 66(3) of the Income-tax Act, 1922 cannot be compelled where the proposed question does not arise from the appellate order and the controversy is purely factual. The assessment authorities treated an amount as profits on the basis of the books of account, the assessee's explanation that it was a gift from his aunt, and the absence of supporting evidence. The Court held that the matter depended on appreciation of evidence and factual inference, not on any question of law, and the request for reference was therefore refused. en-us Mon, 16 Sep 1940 00:00:00 +0530 Sat, 18 Jan 2020 14:17:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=285594 A reference under Section 66(3) of the Income-tax Act, 1922 cannot be compelled where the proposed question does not arise from the appellate order and the controversy is purely factual. The assessment authorities treated an amount as profits on the basis of the books of account, the assessee's explanation that it was a gift from his aunt, and the absence of supporting evidence. The Court held that the matter depended on appreciation of evidence and factual inference, not on any question of law, and the request for reference was therefore refused. Case-Laws Income Tax Mon, 16 Sep 1940 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=285594