Substantial question of law threshold barred interference where factual findings supported attempted tax evasion and penalty.

Under section 68 of the Punjab Value Added Tax Act, 2005, appellate interference was confined to a substantial question of law, and the High Court would not reappreciate pure findings of fact. The departmental authorities and the Tribunal relied on the intercepted goods, discrepant documents produced by the driver, absence of a GR or trip sheet, the belated bill said to have been issued from Ropar, and the failure to produce books of account to prove genuineness. On those materials, the finding of attempted tax evasion and the penalty order were based on fact and raised no substantial question of law, so they were not disturbed.

---

---

Issues: Whether the appeal under section 68 of the Punjab Value Added Tax Act, 2005 raised any substantial question of law warranting interference with the concurrent findings that the assessee had attempted to evade tax and was liable to penalty.

Analysis: The findings recorded by the departmental authorities and the Tribunal were based on the factual materials regarding the intercepted goods, the discrepant documents produced by the driver, the absence of a GR or trip sheet, the belated bill said to have been issued from Ropar, and the failure to produce books of account to establish genuineness. In the appellate framework under section 68(3) and (4) of the Act, interference is confined to a substantial question of law and the court does not reappreciate pure findings of fact. No such question arose on the record.

Conclusion: The appeal did not give rise to any substantial question of law and the findings of fact and penalty order were not liable to be disturbed.

---