Mandatory pre-deposit and missing records defeated the service tax challenge, with no substantial question of law arising.

Non-compliance with the mandatory pre-deposit requirement under the service tax framework, together with failure to place the show-cause notice and other relied-upon materials on record, left the Tribunal's dismissal of the appeal without a substantial question of law. The Court noted that the absence of supporting records was material to the challenge and treated the defect as fatal to interference. Condonation of delay was dealt with separately, but it did not alter the merits position or revive the appeal. The challenge therefore failed on the basis that no substantial question of law was made out.

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Issues: Whether any substantial question of law arose from the Tribunal's order dismissing the appeal for non-compliance with the mandatory pre-deposit requirement and for want of supporting records.

Analysis: The Tribunal had found non-compliance with the mandatory pre-deposit requirement under the applicable service tax framework and also noted that the supporting documents, including the show-cause notice and materials relied upon in the appeal, had not been placed on record. On review, the Court found no substantial question of law arising from that order. The delay in filing the appeal was separately condoned, but that did not affect the merits of the challenge.

Conclusion: No substantial question of law was made out, and the challenge to the Tribunal's order failed.

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