Concurrent findings of fact in customs dispute barred interference, as no question of law arose and the appeal was dismissed.

Concurrent factual findings by the Commissioner (Appeals) and the Tribunal were based on the absence of reliable evidence of the importer's actual payment and on the unreliability of the departmental invoice, which was unsigned and discrepant. The High Court treated these conclusions as pure findings of fact and found no legal infirmity in the view that the proceedings against the importer were not sustainable on the available material. As no question of law, much less a substantial question of law, arose, the customs appeal was not entertained and was dismissed.

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Issues: Whether the customs appeal raised any question of law warranting interference with the concurrent factual findings of the Commissioner (Appeals) and the Tribunal.

Analysis: The findings recorded by the appellate authorities were based on the absence of reliable evidence regarding the actual payment made by the importer and on the discrepancy in the invoice relied upon by the department. The invoice said to show a higher price was found to be unsigned and unreliable. These were treated as pure findings of fact, and no legal infirmity was shown in the concurrent view that proceedings against the importer were not sustainable on the material available.

Conclusion: No question of law, much less a substantial question of law, arose for adjudication. The appeal was not entertained and was dismissed.

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