https://www.taxtmi.com/caselaws?id=24621 A question can be directed for reference only if it actually arises from the Tribunal's order; issues based on factual contentions not urged before the Tribunal are outside that jurisdiction. The text also states that a finding that a person owned contraband goods or was concerned in acquiring, keeping, concealing, or dealing with them, when reached on appreciation of evidence, is a finding of fact. Mere disagreement with evidentiary appraisal does not convert such a finding into a referable question of law. On that basis, proposed reference questions were treated as non-referable, either because they did not arise from the record or because they attacked factual findings. en-us Fri, 15 May 1987 00:00:00 +0530 Thu, 21 Jan 2010 12:44:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=24621 A question can be directed for reference only if it actually arises from the Tribunal's order; issues based on factual contentions not urged before the Tribunal are outside that jurisdiction. The text also states that a finding that a person owned contraband goods or was concerned in acquiring, keeping, concealing, or dealing with them, when reached on appreciation of evidence, is a finding of fact. Mere disagreement with evidentiary appraisal does not convert such a finding into a referable question of law. On that basis, proposed reference questions were treated as non-referable, either because they did not arise from the record or because they attacked factual findings. Case-Laws Income Tax Fri, 15 May 1987 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=24621