No substantial question of law arises where concurrent findings show no abetment of smuggling and no penalty liability.

Concurrent findings that the respondent had not abetted the smuggling of cars were upheld because the record showed no act or omission linking the respondent to the illegal export. The High Court found the dispute turned entirely on factual appreciation, with no legal error in the Tribunal's order, so no substantial question of law arose under Section 130 of the Customs Act, 1962. On that basis, penalty under Section 114 of the Customs Act, 1962 was not warranted.

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Issues: Whether any substantial question of law arose from the Tribunal's finding that the respondent had not abetted the smuggling of cars and was therefore not liable to penalty under the Customs Act, 1962.

Analysis: The authorities below had recorded concurrent findings that the respondent was not involved in abetting the illegal export of cars. Those findings were based on the record, including the Commissioner's own observations and the Tribunal's conclusion that there was no material showing any act or omission by the respondent contributing to the smuggling. As the dispute turned entirely on factual appreciation and no legal error was shown in the Tribunal's order, the matter did not give rise to a substantial question of law under Section 130 of the Customs Act, 1962.

Conclusion: The issue was decided against the Revenue and in favour of the respondent; the penalty under Section 114 of the Customs Act, 1962 was not warranted.

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