https://www.taxtmi.com/caselaws?id=24215 A reference under section 256(2) is not warranted where the Tribunal's refusal to state a case turns on material already on record and on factual appreciation of an admitted position. The dispute concerned whether interest liability had crystallised in an earlier assessment year, making the later claim unavailable, and whether rectification under section 154 was relevant on those facts. As the controversy depended on the contents of the record rather than on a disputed question of law, no referable question of law arose. The request for a direction to state a case was therefore refused. en-us Mon, 23 Feb 1987 00:00:00 +0530 Mon, 18 Jan 2010 15:49:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=24215 A reference under section 256(2) is not warranted where the Tribunal's refusal to state a case turns on material already on record and on factual appreciation of an admitted position. The dispute concerned whether interest liability had crystallised in an earlier assessment year, making the later claim unavailable, and whether rectification under section 154 was relevant on those facts. As the controversy depended on the contents of the record rather than on a disputed question of law, no referable question of law arose. The request for a direction to state a case was therefore refused. Case-Laws Income Tax Mon, 23 Feb 1987 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=24215