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Issues:
1. Assessment of penalty under section 18(1)(c) of the Wealth-tax Act for the assessment years 1966-67 and 1973-74. 2. Justification of the Appellate Tribunal's conclusion on the imposition of a penalty on the assessee. Analysis: The judgment pertains to multiple cases involving the same question of law against the same assessee, which were disposed of by a common order. Initially, for the assessment years 1966-67 and 1973-74, the assessee was penalized for concealing wealth by the Wealth-tax Officer. However, the appellate authority found the assessee's explanation satisfactory and set aside the penalty. Subsequently, the Department appealed to the Tribunal, which dismissed the appeal. The Tribunal was then approached for a reference under section 27 of the Wealth-tax Act, resulting in a question being referred to the High Court. The High Court ruled in favor of the assessee, emphasizing that the Tribunal's decision was based on factual findings and no question of law arose. In another set of cases relating to assessment years prior to 1973-74, similar appeals were made by the Revenue against orders passed by the Commissioner of Wealth-tax. The Tribunal dismissed these appeals as well, prompting the Department to seek a reference before the High Court. The Department framed a question regarding the imposition of a penalty under section 18(1)(c) of the Wealth-tax Act, which mirrored the previous case. The High Court, after considering the arguments and records, reiterated that since the Tribunal had already determined that the assessee had satisfactorily explained the facts and there was no concealment of wealth, no question of law arose. The High Court cited a previous order where it was held that the Tribunal's factual findings precluded the application of section 18(1)(c) of the Act, leading to the rejection of the reference applications. Ultimately, the High Court rejected all reference applications from the Revenue, emphasizing that the matter had already been decided based on factual assessments. The court reiterated that the question of whether the assessee had provided a satisfactory explanation was a question of fact, and since the Tribunal and the Commissioner were satisfied with the explanation, no legal issue was present. The court's decision was guided by the principle that no question of law arose when the facts had been adequately addressed and explained, as evidenced by the previous rulings and the specific circumstances of the cases at hand.
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