Revisional jurisdiction and absence of tax-evasion intent barred interference with release of seized goods.

Revisional jurisdiction is limited to questions arising from the Tribunal's order, so a ground not raised before the Tribunal and not dealt with by it cannot ordinarily be introduced in revision. The Court therefore rejected the new ground. On the seizure issue, the Tribunal's factual finding that the transactions were duly recorded and that there was no material showing intent to evade tax was not shown to be perverse. The seizure of goods and demand for security were therefore unjustified, and the order directing release of the goods was sustained.

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Issues: (i) Whether a ground not raised before the Tribunal can be taken in revision. (ii) Whether the seizure of goods and demand of security for release of goods was justified in the absence of material showing intent to evade tax.

Issue (i): Whether a ground not raised before the Tribunal can be taken in revision.

Analysis: The revisional jurisdiction is confined to questions arising out of the Tribunal's order. A ground neither raised before the Tribunal nor dealt with by it cannot ordinarily be entertained in revision. Only questions considered by the Tribunal, or deemed to have been considered because they were raised there, fall within the revisional scope.

Conclusion: The new ground could not be taken in revision.

Issue (ii): Whether the seizure of goods and demand of security for release of goods was justified in the absence of material showing intent to evade tax.

Analysis: The Tribunal found, as a matter of fact, that the agreements, job-work arrangements, and related entries were duly recorded in the books and records. That finding was not shown to be perverse or contrary to the material on record. In such circumstances, the conclusion that there was no intention to evade tax and that insistence on security was unwarranted was not open to interference.

Conclusion: The seizure and the demand for security were not justified.

Final Conclusion: The revision failed and the Tribunal's order directing release of the goods was sustained.

Ratio Decidendi: Revisional interference is confined to questions arising from the Tribunal's order, and a factual finding of no tax-evasion intent, unless perverse, is not open to challenge in revision.

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