Transport document irregularities justified tax penalty where concurrent findings showed attempted evasion and no substantial question of law arose.

Penalty under the Punjab Value Added Tax Act, 2005 was upheld where the Tribunal found that the transport documents were incomplete, unavailable at detention, and capable of indicating later manipulation, supporting an inference of withholding documents with an attempt to evade tax. The Court found no illegality or perversity in those concurrent factual findings and held that they justified the statutory penalty. It further held that, on those facts, no substantial question of law arose from the Tribunal's order, so the challenge failed.

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Issues: Whether penalty under the Punjab Value Added Tax Act, 2005 was justified on the facts found by the Tribunal, and whether any substantial question of law arose from the Tribunal's order.

Analysis: The goods were detained because the driver did not produce the goods receipt when required, and the Tribunal found that the relevant document had been left incomplete, was not available at the time of detention, and was capable of supporting an inference that it had been manipulated later. On those facts, the Tribunal concluded that the conduct amounted to withholding or producing incomplete documents with an attempt to evade tax due or likely to be due. No illegality or perversity in those findings was shown before the Court, and the concurrent findings of the authorities below supported the levy of penalty under the statutory provisions governing movement of goods and penalty.

Conclusion: The penalty was upheld and no substantial question of law arose; the challenge failed.

Final Conclusion: The statutory penalty survived on the basis of concurrent factual findings showing attempted tax evasion through incomplete and withheld transport documents.

Ratio Decidendi: Concurrent findings of fact that transport documents were incomplete or withheld with an inference of attempted tax evasion will not give rise to a substantial question of law in a tax penalty appeal absent perversity or illegality.

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