Substantial question of law threshold governs High Court excise appeals; vague factual grounds were insufficient for admission.

A High Court appeal under Section 35G of the Central Excise Act, 1944 lies only if it raises a substantial question of law arising from the record, and the Court treated this jurisdictional test as pari materia with Section 260A of the Income-tax Act, 1961. The grounds were found to be largely factual, vague, and unsupported by material showing that the alleged documentary evidence had been considered by the authorities below. As no arguable legal question emerged from the record, the Court held that no substantial question of law was made out and the appeal was not maintainable.

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Issues: Whether the appeal disclosed any substantial question of law so as to warrant admission under Section 35G of the Central Excise Act, 1944.

Analysis: The appeal was examined on the footing that only a substantial question of law could confer jurisdiction on the High Court. The grounds raised were found to be largely factual, vague, or unsupported by material showing that the alleged documentary evidence had been considered by the authorities below. The Court relied on settled principles that a substantial question of law must arise from the record and cannot rest on conjecture, and it treated the test under Section 35G of the Central Excise Act, 1944 as pari materia with Section 260A of the Income-tax Act, 1961. On that basis, the Court held that no substantial question of law arose.

Conclusion: No substantial question of law was made out, and the appeal was not maintainable.

Ratio Decidendi: A High Court appeal under Section 35G of the Central Excise Act, 1944 lies only when the case involves a substantial question of law arising from the record; purely factual disputes or vague grounds do not satisfy that jurisdictional requirement.

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