Writ court will not disturb concurrent factual findings where excise exemption depends on proof of duty-paid inputs

Entitlement to excise duty exemption on mixed fertilisers depended on proof that the base materials had actually suffered duty. The departmental authorities concurrently found that the evidence did not reliably link the petitioner's inputs to the consignments on which duty was said to have been paid, and that factual finding was not disturbed. In writ jurisdiction, the HC would not reassess the adequacy or probative value of disputed evidence or act as an appellate forum on facts. The petitions were therefore rejected, as no jurisdictional or legal infirmity was shown in the impugned orders.

---

---

Issues: Whether the petitioner was entitled to exemption or set-off of excise duty on mixed fertilisers on the basis that duty had been paid on the base materials used in their manufacture, and whether the High Court could interfere in writ jurisdiction with the concurrent factual findings of the departmental authorities.

Analysis: The claim for exemption depended on proof that the base materials used in the granulated mixed fertilisers had in fact suffered duty. The authorities concurrently found that the evidence produced did not establish a reliable link between the materials purchased by the petitioner and the imported consignments on which duty had allegedly been paid. The Court held that, in writ proceedings, it could not reassess the adequacy or probative value of the evidence or act as an appellate forum to substitute its own view on disputed questions of fact.

Conclusion: The petitioner failed to establish entitlement to the claimed duty exemption, and the concurrent factual findings were not open to interference in writ jurisdiction.

Final Conclusion: The writ petitions were rejected because no jurisdictional or legal infirmity was shown in the impugned orders, and the findings on duty payment and exemption remained undisturbed.

Ratio Decidendi: A writ court will not interfere with concurrent factual findings on the sufficiency of evidence unless a legal or jurisdictional error is shown, particularly where entitlement to fiscal exemption depends on proof of duty-paid inputs.

---