Final fact-finding authority's classification stands where evidence supports it and no perversity is shown

A factual finding by the final fact-finding authority under the APGST Act will not be disturbed on revision unless it is perverse or unsupported by legally admissible evidence. On the evidence before it, the Tribunal concluded that cable sheathing compound remained an article of plastic under entry 186 because LDPE granules were only compounded with additives and no new substance emerged. The High Court held that this was a pure question of fact, declined to reappreciate the sufficiency of evidence, and found that no question of law arose under section 22(1). The Tribunal's classification was therefore left undisturbed.

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Issues: Whether the Tribunal's finding that the cable sheathing compound remained an article of plastic falling under entry 186 of the First Schedule to the Andhra Pradesh General Sales Tax Act, 1957 was perverse or unsupported by evidence, and whether any question of law arose for interference under section 22(1) of the Act.

Analysis: The Tribunal was the final fact-finding authority under the APGST Act. The dispute turned on a pure question of fact as to the nature of the product after processing. The Court held that interference with such a finding was permissible only if the finding was perverse or based on no legally admissible evidence. Since the Tribunal had relied on material showing that LDPE granules were only compounded with additives and no new substance emerged, the finding could not be treated as perverse. The Court also held that it could not reappreciate the adequacy or sufficiency of the evidence once some substantive evidence supported the Tribunal's conclusion.

Conclusion: The Tribunal's classification of the product under entry 186 was upheld and no question of law arose for interference under section 22(1) of the Andhra Pradesh General Sales Tax Act, 1957.

Final Conclusion: The revision cases were rejected and the Tribunal's factual determination was left undisturbed.

Ratio Decidendi: A factual finding by the final fact-finding authority under the sales tax law will not be interfered with unless it is perverse or unsupported by any legally admissible evidence; mere disagreement with the sufficiency of evidence does not raise a question of law.

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