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Reference---   --Findings of fact- Jurisdiction of High Court arid Supreme Court-Non-acceptance of explanations given by assessee -Whether gives rise to question of law-Assessment order-Ofcer- Whether assessee entitled to opportunity to adduce fresh evidence or explanation to refute reasons formulated in order-Income-tax Act (XI of 1922), Ss. 23 (3) & 66 (1)-Scope of.   The High Court in a reference under the Income-tax Act, 1922 and the Supreme Court in an appeal from the judgment of the High Court on such reference, do not sit as ordinary Courts of Appeal in the matter of assessments. With reference to question of fact the only question which the High Court or the Supreme Court has to consider is whether there was any material before the Tribunal to support the finding of fact recorded by the Tribunal.   Where under the head "wages and salaries" the return of a particular year showed a considerable increase over the amount shown under the head in the previous year and the income-tax authorities, rejecting the explanation given by the assessee for the absence of receipts for some payments, held that the wages had been inflated and added back those amounts to the income:   Held, (i) that the finding of the authorities that the wages had been inflated was a finding of fact and that this finding could not be held to be based on no material ;   (ii) that the non-acceptance of the explanations given by the assessee could not convert the question of inflation of wages which was essentially a question of fact into a question of law.   Held also, that section 23 (3) of the Income-tax Act, 1922, does not contemplate that with regard to every reason which is formulated by the Income-tax Officer in his order, the assessee must be given an opportunity to produce fresh evidence or fresh explanation JUDGMENT   S. K. DAS, J.-Messrs Newton Chikli Collieries Limited, a private company registered under the Indian Companies Act, is the assessee-appellant before us. It carried on the business of raising coal from a group of collieries known as the Newton Chikli Collieries. The controlling interest in the assessee company was with…