Revisional jurisdiction limited to questions of law cannot disturb concurrent factual findings unless a legal infirmity is shown.

Revisional jurisdiction under Section 11 of the Uttar Pradesh Trade Tax Act is confined to questions of law and must be exercised on precisely formulated legal issues. Where the departmental authorities and the Tribunal have recorded concurrent factual findings, based on physical verification and examination of documents, that the goods in the vehicle did not match the transit papers, the High Court cannot interfere merely because another view of the evidence is possible. Absent any demonstrated infirmity in those findings, revisional interference on facts is impermissible. The principle is that bona fide concurrent findings of fact cannot be disturbed in revision limited to questions of law.

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Issues: (i) Whether the High Court, in revision under Section 11 of the Uttar Pradesh Trade Tax Act, 1948, was justified in interfering with the concurrent factual findings of the departmental authorities and the Tribunal regarding discrepancy in the goods carried under the transit documents.

Analysis: The revisional jurisdiction under Section 11 is confined to questions of law, which must be precisely stated and formulated. The departmental authorities and the Tribunal had recorded factual findings, after physical verification and examination of documents, that the goods found in the vehicle were not the same as those covered by the transit pass and related papers. The High Court interfered without demonstrating any infirmity in those findings. In such a situation, a different possible view on facts is not a ground for interference, particularly where the fact-finding authorities acted honestly and bona fide and the jurisdiction is limited to questions of law.

Conclusion: The High Court was not justified in disturbing the concurrent findings of fact, and the interference was unwarranted.

Final Conclusion: The appellate court restored the departmental and Tribunal findings and held that revisional interference on the facts of the case was impermissible.

Ratio Decidendi: In a revision confined to questions of law, concurrent findings of fact cannot be interfered with merely because another view on the evidence is possible.

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