Factual valuation dispute over seized goods and weight did not raise a substantial question of law.

The challenge to the valuation of seized goods and the method of determining weight was treated as a factual dispute based on the seizure material, invoices, mahazars and admissions by the partners and directors. The finding that the wooden drums had already been deducted, and that discrepancies in description, size, quantity and weight were supported by contemporaneous records, was not shown to suffer from any legal error. The court held that the issue did not give rise to a substantial question of law, and the valuation and weight-related finding was left undisturbed.

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Issues: Whether a substantial question of law arose on the valuation of seized goods and the method of determining their weight.

Analysis: The valuation dispute turned on the factual appreciation of the seizure material, the invoices, the mahazars and the statements of the partners and directors. The Commissioner had recorded that the weight of the wooden drums had already been deducted and that the discrepancies in description, size, quantity and weight were supported by the contemporaneous records and admissions. The challenge before the appellate forum was found to be largely factual, and the court was not persuaded that the written submissions said to have been filed before the Tribunal established any failure to consider the specific weight-related objection so as to give rise to a substantial question of law.

Conclusion: No substantial question of law arose; the valuation and weight-related finding was left undisturbed and the challenge failed.

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