https://www.taxtmi.com/caselaws?id=61341 Full disclosure of the primary facts in Part III of the return was treated as a pure finding of fact, and on that basis penalty under Section 271(1)(c) was not shown to raise any independent legal issue. Because the proposed questions for reference depended entirely on that factual finding, no referable question of law arose under Section 256(1), and the consequential penalty-related question also did not merit reference. The request to state the case and refer the questions was therefore rightly declined. en-us Fri, 31 Jan 1986 00:00:00 +0530 Wed, 12 Jan 2011 12:42:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=61341 Full disclosure of the primary facts in Part III of the return was treated as a pure finding of fact, and on that basis penalty under Section 271(1)(c) was not shown to raise any independent legal issue. Because the proposed questions for reference depended entirely on that factual finding, no referable question of law arose under Section 256(1), and the consequential penalty-related question also did not merit reference. The request to state the case and refer the questions was therefore rightly declined. Case-Laws Income Tax Fri, 31 Jan 1986 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=61341