Plausible factual finding on no tax evasion did not raise a substantial question of law in appellate review.

A fact-based finding that goods were supported by invoices and a bound bill book, and that the declaration discrepancy arose from a computer-entry mistake, was treated as a plausible view of the evidence. On that basis, the Tribunal's conclusion that there was no attempt to evade tax under the Punjab Value Added Tax Act, 2005 did not give rise to any substantial question of law. The High Court therefore declined interference with the Tribunal's factual determination, and the Revenue's challenge failed.

---

---

Issues: Whether the Tribunal's finding that there was no attempt to evade tax under the Punjab Value Added Tax Act, 2005 gave rise to a substantial question of law warranting interference in appeal.

Analysis: The Tribunal had found, on the facts, that the driver had produced the relevant documents, the goods were covered by invoices and a bound bill book, and the discrepancy in declaration was attributable to a mistake in noting particulars in the computer. On this basis, the Tribunal concluded that non-declaration at the check-post was not with a view to evade tax. The High Court held that this conclusion represented a plausible view on the evidence and, therefore, did not raise any substantial question of law.

Conclusion: The finding of no attempt to evade tax was upheld and no substantial question of law arose; the issue was decided against the Revenue and in favour of the assessee.

Final Conclusion: Interference with the Tribunal's factual determination was unwarranted, and the Revenue's appeal failed.

Ratio Decidendi: A fact-based finding that there was no attempt to evade tax, if it represents a plausible view on the evidence, does not constitute a substantial question of law for appellate interference.

---