No substantial question of law arose where the Tribunal found no wilful suppression and held the service tax work exempt.

The Tribunal's finding that there was no wilful suppression of facts defeated invocation of the extended period of limitation, and that factual conclusion was accepted on review. The Tribunal also held, after analysing the service tax law and earlier decisions, that the respondent-assessee's work was exempt. Because the challenge depended on those factual findings and on settled legal principles, the Court held that no substantial question of law arose for interference under section 35G. The revenue appeal therefore failed and the Tribunal's conclusions were left undisturbed.

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Issues: Whether the Tribunal's finding that there was no wilful suppression of facts and that the extended period of limitation was unavailable gave rise to any substantial question of law.

Analysis: The Tribunal had recorded a finding of fact that there was no wilful suppression of facts and, on that basis, held that the extended period of limitation could not be invoked. It had also held, after detailed discussion of the relevant service tax law and earlier decisions, that the work carried out by the respondent-assessee was exempt. The challenge before the Court therefore turned on findings already recorded on facts and on the settled legal position, leaving no independent legal issue requiring interference.

Conclusion: The question was answered against the appellant and in favour of the assessee. No substantial question of law arose.

Final Conclusion: The revenue appeal did not succeed, as the Tribunal's factual and legal conclusions were left undisturbed.

Ratio Decidendi: Where the Tribunal's decision rests on a factual finding of no wilful suppression and the resulting non-availability of the extended period of limitation, and the controversy is otherwise covered by settled law, no substantial question of law arises for interference under section 35G.

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