Concurrent factual findings on undervaluation and excise liability were upheld; no perversity or substantial question of law was shown.

Concurrent findings on undervaluation and related excise liability were upheld because the Department failed to produce concrete, corroborative evidence that differential amounts formed part of the rig price, that the invoice model declaration was false to the extent alleged, or that there had been clandestine manufacture or removal of spares and optional items. The Court reiterated that perversity exists only where a finding is unsupported by evidence or no reasonable person could reach it, and that an appeal under Section 35-G of the Central Excise Act lies only on a substantial question of law. The findings were therefore not shown to be perverse and no interference was warranted.

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Issues: Whether the concurrent factual findings of the adjudicating authority and the Tribunal regarding undervaluation and related excise liability suffered from perversity so as to warrant interference in an appeal under Section 35-G of the Central Excise Act, 1944.

Analysis: The assessment of valuation and the alleged receipt of amounts over and above invoice prices was founded on appreciation of evidence by the original authority and affirmed by the Tribunal. The Court noted that the Department had not established by concrete and corroborative evidence that the differential amounts formed part of the price of the rigs, that the model declared in the invoices was false to the extent alleged, or that there had been clandestine manufacture or removal of spares and optional items. It reiterated that perversity arises only where a finding is unsupported by evidence or no reasonable person could have reached it, and that an appeal under Section 35-G lies only on a substantial question of law. On the record, the concurrent findings were reasoned, evidence-based, and free from any such infirmity.

Conclusion: The findings were not shown to be perverse and no substantial question of law arose for interference.

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