Limitation and fraud or suppression findings based on evidence do not raise a substantial question of law absent perversity.

The demand for the period beyond the normal limitation period could be reopened only on proof of fraud or suppression by the processors. On the record, no material showed personal knowledge of the alleged inflation in valuation of grey fabric, and the Dyeing Master's statement was insufficient to establish fraud or suppression. The Tribunal's finding was based on appreciation of evidence, was a possible view, and was not shown to be perverse. Accordingly, no substantial question of law arose on limitation or alleged fraud or suppression, and the Revenue's challenge failed.

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Issues: Whether the Tribunal's view that the demand for the period other than December 2002 was barred by limitation was perverse or gave rise to any substantial question of law, in the absence of evidence establishing fraud or suppression by the processors.

Analysis: The disputed period, apart from December 2002, lay beyond the normal limitation period and could be reopened only if fraud or suppression was established on evidence. The record showed no material proving that the processors had personal knowledge of the inflation in valuation of grey fabric or that the Dyeing Master's statement was sufficient to establish fraud or suppression. The finding turned on appreciation of evidence and was not shown to be impossible or perverse. In such circumstances, the Tribunal's view remained a possible view and did not justify interference in appeal.

Conclusion: The question of limitation and alleged fraud or suppression did not give rise to any substantial question of law. The Revenue's challenge failed.

Ratio Decidendi: Where the disputed demand beyond the normal limitation period depends on proof of fraud or suppression, and the fact-finding authority records a possible finding that such evidence is lacking, no substantial question of law arises unless perversity is demonstrated.

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