Reasonable cause and composite penalty findings were factual, so no question of law arose for revision.

A determination of reasonable cause for failure to furnish returns or pay tax under the Rajasthan Sales Tax Act, 1954 was treated as a finding of fact, not a question of law capable of revision under section 15. The tribunal also noted that the penalty was composite and did not clearly separate the part attributable to delayed filing of returns from the part attributable to non-payment of tax. On that basis, no legal question survived for reference or revision, and the revision application was held not maintainable in favour of the Revenue.

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Issues: Whether any question of law arose from the order imposing penalty under section 16(1)(c) of the Rajasthan Sales Tax Act, 1954 so as to sustain the revision application.

Analysis: The finding as to reasonable cause for failure to furnish returns or pay tax turned on the facts and circumstances of the case. Such a determination was not a question of law fit for revision under section 15 of the Rajasthan Sales Tax Act, 1954. The order of the Board was also supported by the further reason that the penalty was composite and did not clearly separate the part attributable to delayed filing of returns from that attributable to non-payment of tax. On that footing, no legal question survived for reference or revision.

Conclusion: No question of law arose and the revision application was not maintainable. The decision went in favour of the Revenue.

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