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Issues: Whether the Tribunal was justified in sustaining penalty under Section 51(7)(c) of the Punjab Value Added Tax Act, 2005 on the basis that the goods were carried with concealment of part of the invoice and with an intention to evade tax, and whether any interference was warranted with the Tribunal's finding deleting penalty under Section 51(12) of the Punjab Value Added Tax Act, 2005.
Analysis: The Tribunal recorded concurrent findings that 55 multipara monitors were in the vehicle, that only an invoice for 30 monitors was produced at the time of interception, that the information earlier furnished to the authorities also reflected only 30 monitors, and that the later invoice for the remaining 25 monitors appeared to have been generated after detention of the goods. On these facts, the Tribunal inferred an intention to evade tax and sustained penalty under Section 51(7)(c), while holding that no offence under Section 51(12) was made out because the consignor and consignee details had been disclosed. In the absence of any demonstrated illegality or perversity in these findings, no substantial question of law arose for interference.
Conclusion: The penalty under Section 51(7)(c) was upheld and the deletion of penalty under Section 51(12) stood confirmed; the appeal was not entitled to interference.
Ratio Decidendi: Where findings of fact reasonably establish concealment of goods and an intention to evade tax, and those findings are neither illegal nor perverse, no substantial question of law arises for interference in revision or appeal under the PVAT Act.