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    <title>1991 (10) TMI 15 - ALLAHABAD High Court</title>
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    <description>In a tax reference under section 256, a finding that there was no conscious concealment, fraud or wilful neglect for penalty under section 271(1)(c) was treated as a finding of fact, so no referable question of law arose. The High Court could not disturb that factual conclusion merely by treating it as unsupported by evidence. It also could not reframe the proposed question to introduce a new challenge to findings of fact that had not been specifically raised in the reference application. The ruling confirms that reference jurisdiction is confined to questions arising from the Tribunal&#039;s order and properly raised before it.</description>
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    <pubDate>Thu, 10 Oct 1991 00:00:00 +0530</pubDate>
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      <title>1991 (10) TMI 15 - ALLAHABAD High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=21377</link>
      <description>In a tax reference under section 256, a finding that there was no conscious concealment, fraud or wilful neglect for penalty under section 271(1)(c) was treated as a finding of fact, so no referable question of law arose. The High Court could not disturb that factual conclusion merely by treating it as unsupported by evidence. It also could not reframe the proposed question to introduce a new challenge to findings of fact that had not been specifically raised in the reference application. The ruling confirms that reference jurisdiction is confined to questions arising from the Tribunal&#039;s order and properly raised before it.</description>
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      <pubDate>Thu, 10 Oct 1991 00:00:00 +0530</pubDate>
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