I. C. I. (INDIA) PRIVATE LTD. vs C. I. T., WEST BENGAL

The Supreme Court held that the High Court has jurisdiction to direct the Tribunal to refer questions when they involve pure questions of law or mixed questions of law and fact. The Court clarified that under Section 52 of the Income-tax Act, 1961, the necessary conditions for assessing capital gains tax include a direct or indirect connection between the acquirer and the assessee, and the Income-tax Officer must have reason to believe that the transfer was made to avoid tax liability. The Court upheld the Tribunal's findings, emphasizing that the intention behind a transfer is a question of fact that must be substantiated by relevant material.