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Issues: Whether the Tribunal's findings on manufacture, job work arrangement, and duty liability gave rise to any substantial question of law warranting interference.
Analysis: The Tribunal's conclusions were based on documentary material, seized records, and the parties' statements. The High Court found no perversity or legal infirmity in those findings. It held that the controversy was essentially factual, including the nature of the goods sent to the job worker, the manner in which the transactions were recorded, and the claim that duty liability had been shifted to the job worker. As the conclusions of the Tribunal rested on appreciation of evidence, no substantial question of law arose.
Conclusion: The appeal was dismissed and the Tribunal's findings were left undisturbed.
Ratio Decidendi: Concurrent findings of fact, when supported by evidence and free from perversity, do not give rise to a substantial question of law in an excise appeal.