Limitation and substantial question of law defeated interference with the Tribunal's order in a delayed demand dispute.

A demand raised after a two-year delay from the inspection was treated as time-barred, and the assessee's retraction remained unrebutted by the Department. On that basis, the Tribunal's order allowing the appeal was found to disclose no legal infirmity, and no substantial question of law arose for interference. The High Court therefore left the Tribunal's order undisturbed and dismissed the appeal.

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Issues: Whether the demand was barred by limitation and whether any substantial question of law arose for interference with the Tribunal's order.

Analysis: The Department issued the show cause notice after a delay of two years from the date of inspection. The demand was treated as time-barred, and the retraction made by the assessee was noted as not having been controverted by the Department. In these circumstances, the Tribunal's order allowing the appeal did not disclose any legal infirmity, and no substantial question of law was found to arise.

Conclusion: The appeal was dismissed and the Tribunal's order was left undisturbed.

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