https://www.taxtmi.com/caselaws?id=24811 In an application under section 256(2) of the Income-tax Act, 1961, a reference could not be compelled where the Tribunal's conclusion that the departmental circular's conditions were satisfied rested on appreciation of the record and was therefore a finding of fact. Mere disagreement with that factual finding did not create a question of law. The Revenue's separate objection based on additional evidence under rule 46A of the Income-tax Rules, 1962 was not the issue actually sought to be referred. The application was therefore not maintainable on the question proposed for reference. en-us Fri, 15 Jul 1988 00:00:00 +0530 Fri, 22 Jan 2010 15:40:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=24811 In an application under section 256(2) of the Income-tax Act, 1961, a reference could not be compelled where the Tribunal's conclusion that the departmental circular's conditions were satisfied rested on appreciation of the record and was therefore a finding of fact. Mere disagreement with that factual finding did not create a question of law. The Revenue's separate objection based on additional evidence under rule 46A of the Income-tax Rules, 1962 was not the issue actually sought to be referred. The application was therefore not maintainable on the question proposed for reference. Case-Laws Income Tax Fri, 15 Jul 1988 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=24811