- (1.) The High Court declined to call for a reference of the following questions: "1. Whether on the facts and in the circumstances of the case, the Tribunal is right in law in holding that the levy of penalty of the sale consideration of the sale of land is justified
(2.) It did so on the basis that they were questions of fact.
(3.) We have perused the order of the High Court and heard learned Counsel and are in no doubt that the High Court was right. The Appellate Tribunal having arrived at the finding of concealment of income on the basis of the material on record, no question of law arose, reference of which could be called for.;