Substantial question of law review fails where factual findings support attempted tax evasion and breach of mandatory transport documents.

An appeal under section 68(1) of the Punjab Value Added Tax Act, 2005 lies only on a substantial question of law, so concurrent factual findings generally will not justify interference. The Tribunal's finding that the goods were moved without mandatory documents under section 51(2), remained unexplained at Bathinda for about twenty days, and supported an inference of attempted tax evasion was based on evidence and disclosed no legal error. The penalty under section 51 was therefore upheld, and no substantial question of law arose.

---

---

Issues: Whether the Tribunal's finding of attempted evasion of tax and the consequential penalty under section 51 of the Punjab Value Added Tax Act, 2005 gave rise to any substantial question of law warranting interference in appeal under section 68(1) of the Act.

Analysis: The appeal jurisdiction under section 68(1) extends only to cases involving a substantial question of law. The Tribunal had recorded factual findings that the goods were carried without the documents mandatorily required under section 51(2), that there was no satisfactory explanation for the goods being unloaded and retained at Bathinda for about twenty days, and that the circumstances supported an inference of attempted evasion or avoidance of tax. Those findings were based on evidence and did not disclose any legal error.

Conclusion: No substantial question of law arose. The penalty and the Tribunal's order were upheld, and the appeals failed.

Ratio Decidendi: An appeal under section 68(1) of the Punjab Value Added Tax Act, 2005 lies only on a substantial question of law, and concurrent factual findings of attempted tax evasion and breach of mandatory document requirements do not justify interference.

---