Revision on question of law fails where penalty reduction is treated as a discretionary matter under sales tax law.

A revision petition under section 86 of the Rajasthan Sales Tax Act, 1994 lies only where a question of law is involved. Reduction of penalty was treated as an exercise of discretion, and the tribunal held that the facts warranting imposition or reduction of penalty did not, by themselves, raise a question of law. The challenge to the reduced penalty therefore did not satisfy the statutory basis for revision, and the revision petitions were not maintainable.

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Issues: Whether a revision petition under section 86 of the Rajasthan Sales Tax Act, 1994 could be maintained where the challenge was only to reduction of penalty, and whether such reduction involved any question of law.

Analysis: A revision under section 86 lies only when a question of law is involved. The reduction of penalty was treated as a matter of discretion and not as a legal issue capable of revision. The reasoning drew support from authority holding that whether facts justify imposition or reduction of penalty is not, by itself, a question of law.

Conclusion: The challenge to reduction of penalty did not raise any question of law, and the revision petitions were not maintainable.

Ratio Decidendi: Where the statute permits revision only on a question of law, a purely discretionary decision to reduce penalty does not furnish such a question.

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