No substantial question of law arose where the Revenue relied on loose sheets and private records without corroboration.

No substantial question of law arose under Section 35G of the Central Excise Act where the Tribunal had assessed the evidence and found that the Revenue's case was based mainly on loose sheets and a private register without independent corroboration. The High Court held that the Tribunal had properly considered the evidentiary material, including documents allegedly recovered from the assessee's premises, and that no ground existed for appellate interference with those factual findings. Interference with the Tribunal's order was therefore not warranted.

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Issues: Whether any substantial question of law arose under Section 35G of the Central Excise Act, 1944 so as to warrant interference with the Tribunal's order based on appreciation of evidence and the absence of corroboration for the Revenue's case founded on loose sheets and private records.

Analysis: The Tribunal had considered the material on record, including the evidentiary value of the documents allegedly recovered from the assessee's premises, and agreed with the Commissioner (Appeals) that the Revenue's case rested mainly on loose sheets and a private register without independent corroboration. The High Court found that the Tribunal had examined the relevant facts and evidence and that no ground was made out for appellate interference under Section 35G.

Conclusion: No substantial question of law arose. Interference with the Tribunal's order was not warranted, and the appeal failed.

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