Provisional assessment finding held factual, leaving no substantial question of law and no basis for penalty or confiscation.

The Tribunal's finding that the assessments for the relevant period were provisional was treated as a factual conclusion based on the record and as a possible view of the material, with no perversity shown. On that basis, no substantial question of law arose for interference. Accepting provisional assessment also supported the view that no penalty or confiscation could be imposed, so the appeal failed.

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Issues: Whether the Tribunal's finding that the assessments for the relevant period were provisional gave rise to any substantial question of law warranting interference.

Analysis: The finding that the assessments were provisional was based on appreciation of the record before the Tribunal. That finding was not shown to be perverse and represented a possible view on the material available. Once that finding was accepted, the consequent view that no penalty or confiscation could be imposed did not require interference.

Conclusion: The question was purely factual and did not give rise to any substantial question of law. The finding of provisional assessment was sustained, and the appeal failed.

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