Substantial question of law absent where interim deposit order rested on prima facie factual findings about similarity of goods and extended period.

A tribunal's interim direction requiring deposit of 50% of the demand, based on a prima facie view on similarity of goods and the possible application of the extended period, was treated as a fact-based assessment rather than a legal determination. The High Court held that such interim factual findings, including whether the exported goods were similar to goods cleared in the Domestic Tariff Area and whether the Department had been kept uninformed, did not raise a substantial question of law. In the absence of pleaded prejudice or financial hardship before the Tribunal, the grievance was to be pursued before the Tribunal itself, and the appeal was held not maintainable on the issues raised.

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Issues: Whether any substantial question of law arose from the Tribunal's interim order directing deposit of 50% of the demand on a prima facie assessment of similarity of goods and invocation of the extended period.

Analysis: The appeal challenged only prima facie findings recorded for the purpose of an interim order. The alleged errors concerned appreciation of facts, including whether the exported goods were similar to the goods cleared in the Domestic Tariff Area and whether the Department was kept in the dark for invoking the extended period. Such factual assessments made at the stage of interim relief do not give rise to a substantial question of law. In the absence of any pleaded prejudice or financial hardship before the Tribunal, the grievance was one to be pursued before the Tribunal itself, not in the present appeal.

Conclusion: No substantial question of law arose for consideration, and the appeal was not maintainable on the issues raised.

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