Pre-deposit waiver challenge failed as no substantial question of law arose from the Tribunal's prima facie assessment.

An appeal challenging the Tribunal's interim order on waiver of pre-deposit was found not to raise any substantial question of law. The HC held that it would not examine the merits of the dispute at the stage of a challenge to the Tribunal's prima facie view, particularly where conditional waiver had been granted on a preliminary assessment. It also noted that financial hardship had not been raised before either forum. On these facts, the appeal was liable to be dismissed in favour of the Revenue.

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Issues: Whether the appeal against the Tribunal's interim order on waiver of pre-deposit raised any substantial question of law.

Analysis: The Court declined to enter into the merits of the controversy at the stage of a challenge to the Tribunal's prima facie view on pre-deposit. It noted that the Tribunal had granted conditional waiver after a prima facie assessment and that the question of financial hardship had not been raised before either forum. In these circumstances, no substantial question of law arose for consideration.

Conclusion: The appeal did not raise a substantial question of law and was liable to be dismissed, against the assessee and in favour of the Revenue.

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