Concurrent findings on CENVAT credit evidence did not raise a substantial question of law under Section 35G.

Concurrent findings on entitlement to CENVAT credit, based on documents, records, photographs and a Chartered Engineer's certificate, were treated as factual determinations within the appellate authority's competence. As the Tribunal adopted those findings and no legal issue emerged from the appreciation of evidence, no substantial question of law arose under Section 35G of the Central Excise Act, 1944. The revenue's appeal was therefore not maintainable on that ground.

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Issues: Whether any substantial question of law arose in the revenue's appeal under Section 35G of the Central Excise Act, 1944 against concurrent findings granting CENVAT credit.

Analysis: The concurrent findings of the Commissioner (Appeals) and the Tribunal rested on appreciation of documents, records, photographs and a Chartered Engineer's certificate. Such determination lay within the jurisdiction and competence of the appellate authority, and the Tribunal adopted those factual findings. No substantial question of law arose from that factual appreciation.

Conclusion: No substantial question of law arose for consideration under Section 35G of the Central Excise Act, 1944, and the revenue's appeal was not maintainable on that ground.

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