https://www.taxtmi.com/caselaws?id=22560 A reference to the High Court is not warranted where the proposed question is purely factual. The Tribunal's finding that the amount was received with a specific direction to be treated as corpus, and therefore constituted a capital receipt, was based on the material on record. No perversity, disregard of relevant evidence, or finding incapable of being reached on the record was shown. A reference cannot be recast to transform a factual dispute into a fresh case for reference, so no reference was called for. en-us Wed, 13 Feb 1991 00:00:00 +0530 Fri, 11 Dec 2009 11:47:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=22560 A reference to the High Court is not warranted where the proposed question is purely factual. The Tribunal's finding that the amount was received with a specific direction to be treated as corpus, and therefore constituted a capital receipt, was based on the material on record. No perversity, disregard of relevant evidence, or finding incapable of being reached on the record was shown. A reference cannot be recast to transform a factual dispute into a fresh case for reference, so no reference was called for. Case-Laws Income Tax Wed, 13 Feb 1991 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=22560