Turnover determination on REP licence surrender turned on factual findings, leaving no substantial question of law for interference.

Turnover adopted for tax on surrender of a REP licence under the Tamil Nadu General Sales Tax Act was upheld on the basis of concurrent factual findings that the correct turnover was Rs. 22,58,840 and not Rs. 1,51,76,000. The first appellate authority and the Tribunal had examined the records and fixed the turnover on the evidence available, and no contrary material was produced to disturb those findings. As the dispute turned entirely on appreciation of facts and documents, no substantial question of law arose, and the revision failed.

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Issues: (i) Whether any substantial question of law arose in relation to the turnover adopted for tax on surrender of REP licence under the Tamil Nadu General Sales Tax Act, 1959.

Analysis: The first appellate authority and the Tribunal had concurrently examined the records and found that the correct turnover relating to the REP licence surrender was only Rs. 22,58,840/-, and not Rs. 1,51,76,000/-. The dispute turned entirely on appreciation of facts and documents, with no contrary material placed to dislodge those findings. In such circumstances, the court held that the challenge did not raise any legal issue warranting interference.

Conclusion: No substantial question of law arose, and the revision failed.

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