Perversity in factual findings prevented any substantial question of law from arising in the manufacturing activity dispute.

The High Court held that the Tribunal's concurrent factual finding, reached after remand on the material on record, that the assessee had no manufacturing activity and no factory was not perverse. As the finding was a pure question of fact and no perversity was shown, no substantial question of law arose for appellate interference. The Tribunal's finding was therefore upheld and the appeal was not entertained on merits.

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Issues: Whether the Tribunal's finding that there was no factory and no manufacturing activity was perverse or gave rise to any substantial question of law warranting interference in appeal.

Analysis: The appeal arose from the Tribunal's concurrent factual conclusion, recorded after remand and on the basis of the material on record, that the assessee had no manufacturing activity. The High Court held that such a finding of fact could not be characterised as perverse. In the absence of perversity, no substantial question of law arose for consideration in the appeal.

Conclusion: The finding of the Tribunal was upheld and the appeal was not entertained on merits.

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