https://www.taxtmi.com/caselaws?id=49250 Section 34 of the Indian Income-tax Act, 1922, as amended, could not be invoked on a new factual foundation not forming part of the question referred. The dispute turned on the construction of the Raigarh notification on the facts accepted by the Tribunal, including the merger date of Raigarh State in India. The revenue could not enlarge the reference before the High Court or in appeal by relying on an alternate fact pattern that the Tribunal had declined to reopen, and that refusal had become final. The question referred was therefore answered against the revenue. en-us Thu, 28 Oct 1965 00:00:00 +0530 Tue, 19 Aug 2014 09:03:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=49250 Section 34 of the Indian Income-tax Act, 1922, as amended, could not be invoked on a new factual foundation not forming part of the question referred. The dispute turned on the construction of the Raigarh notification on the facts accepted by the Tribunal, including the merger date of Raigarh State in India. The revenue could not enlarge the reference before the High Court or in appeal by relying on an alternate fact pattern that the Tribunal had declined to reopen, and that refusal had become final. The question referred was therefore answered against the revenue. Case-Laws Income Tax Thu, 28 Oct 1965 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=49250