Substantial question of law absent where duty demand and confiscation turn only on factual appreciation of evidence.

Concurrent findings based on appreciation of evidence do not give rise to a substantial question of law absent legal error or perversity. The Tribunal rejected the Department's reliance on a pocket diary, noted inconsistencies with the panchnama, and found the alleged duty demand unsupported by corroborative material. The High Court treated those findings as purely factual and held that no legal issue arose from the record. The appeal was therefore not entertained on merits and was dismissed, leaving the Tribunal's order undisturbed.

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Issues: Whether the appeal raised any substantial question of law in relation to the Tribunal's factual findings on duty demand and confiscation under Rule 173Q(1) of the Central Excise Rules, 1944.

Analysis: The Tribunal had disbelieved the Department's reliance on the pocket diary, noticed discrepancies between the diary entries and the panchnama, and found that the alleged demand was unsupported by corroborative material. The High Court held that these findings were purely factual and that no question of law arose from the record.

Conclusion: The appeal was not entertained on merits and was dismissed.

Final Conclusion: The Tribunal's order was left undisturbed because the controversy was confined to appreciation of evidence and did not raise any legal issue warranting interference.

Ratio Decidendi: Concurrent findings based on appreciation of evidence do not give rise to a substantial question of law in the absence of legal error or perversity.

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