Pure finding of fact under sales tax incentive scheme did not justify revisional interference absent legal error or perversity.

A pure finding that the assessee had proved expansion under the Sales Tax New Incentive Scheme, 1989, did not raise a question of law where the Tax Board had examined the facts and figures and the relevant figures were not shown to have been doubted by the State Level Screening Committee. In revision under section 86(3) of the Rajasthan Sales Tax Act, 1994, interference was unwarranted absent any legal error or perversity, so the finding of expansion and entitlement to incentive benefit was upheld and the revision failed.

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Issues: Whether the finding that the assessee had proved expansion, and its entitlement to incentive benefit under the Sales Tax New Incentive Scheme, 1989, raised any question of law warranting interference in revision.

Analysis: The Tax Board had examined the facts and figures furnished by the assessee and concluded that expansion was proved. The order challenged before the Court proceeded on that factual foundation. The alleged need for verification did not convert the matter into a question of law, especially when the relevant figures were not shown to have been doubted by the State Level Screening Committee. In revision under section 86(3) of the Rajasthan Sales Tax Act, 1994, interference was not justified in the absence of any legal error.

Conclusion: The issue was decided against the applicant and in favour of the assessee; the finding of expansion and entitlement to incentive benefit was upheld.

Final Conclusion: The revision failed because the dispute was purely factual and called for no revisional interference.

Ratio Decidendi: A pure finding of fact, unless shown to involve a legal error or perversity, does not give rise to a question of law warranting revisional interference.

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