Job-work exemption denied for lack of proof of use in duty-paid manufacture; later circular held inapplicable

No substantial question of law arose where the Tribunal's denial of job-work exemption rested on a factual finding that the assessee produced no evidence that the job-worked goods were used in manufacturing duty-paid goods. On that record, the exemption notification could not be applied. The later circular was also held inapplicable to the relevant period, and no retrospective benefit could be claimed from it. The challenge therefore involved settled facts rather than any arguable legal issue, and the denial of exemption was upheld.

---

---

Issues: Whether any substantial question of law arose from the Tribunal's order denying the assessee the benefit of the job-work exemption notification and the later circular.

Analysis: The authorities below had recorded a factual finding that there was no evidence to show that the job-worked goods were used in the manufacture of duty-paid goods. In the absence of such evidence, the assessee could not claim the benefit of the exemption notification. The later circular was also inapplicable to the period in dispute, and no retrospective benefit could be claimed from it. The challenge therefore turned only on settled factual findings and did not raise any arguable question of law.

Conclusion: No substantial question of law arose. The denial of exemption was upheld and the appeal failed.

---