Revisional interference limited to questions of law; C-form benefit upheld for goods used in highway construction.

Revisional interference under section 86 of the Rajasthan Sales Tax Act is confined to a specific question of law, and vague or general grounds do not justify interference. On the facts, no arguable legal error was shown in the concurrent orders, so the revision was not maintainable on that basis. The authorities were also justified in allowing C-form benefit for goods used in construction activity, including diesel, LDO, furnace oil and related materials deployed for national highway construction, because the factual finding supported use for the relevant construction purpose and disclosed no legal error warranting revision.

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Issues: (i) Whether the revision under section 86 of the Rajasthan Sales Tax Act, 1994 disclosed any question of law warranting interference. (ii) Whether the Tax Board was justified in affirming the grant of benefit relating to C-form purchases for goods used in construction activity.

Issue (i): Whether the revision under section 86 of the Rajasthan Sales Tax Act, 1994 disclosed any question of law warranting interference.

Analysis: The revisional power under section 86 is confined to questions of law. The revision petition did not set out any specific legal provision or material showing error in the concurrent orders, and the grounds were found to be vague and general. In the absence of a properly formulated and arguable question of law, interference in revision was not called for.

Conclusion: No question of law arose for interference under section 86.

Issue (ii): Whether the Tax Board was justified in affirming the grant of benefit relating to C-form purchases for goods used in construction activity.

Analysis: The goods purchased, including diesel, LDO, furnace oil and other material, were used for construction of a national highway. The finding was that the goods were used for the relevant processing or construction purpose and that the authorities below had correctly applied the governing principles to the facts of the case.

Conclusion: The Tax Board and the Deputy Commissioner (Appeals) were justified in upholding the dealer's claim.

Final Conclusion: The revisional challenge failed because the record did not disclose any legal error in the concurrent orders and the factual finding regarding use of goods for highway construction was accepted.

Ratio Decidendi: Revisional interference is impermissible in the absence of a specific question of law, and a factual finding that goods were used for the relevant construction or processing purpose will not be disturbed in revision without legal error.

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