Substantial question of law absent where input receipt dispute turned entirely on evidence and recorded factual findings.

The controversy concerned whether the inputs were actually received in the assessee's factory and whether any substantial question of law arose under Section 35G. The Court held that the Tribunal's finding was based on evidence, including transport particulars and an official report showing that the vehicles named in the invoices were not goods transport vehicles capable of carrying the stated consignments. As the assessee failed to produce material to dislodge those factual findings, the matter turned entirely on appreciation of evidence and recorded facts. The Court therefore declined to re-appreciate the evidence and held that no substantial question of law arose.

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Issues: Whether any substantial question of law arose from the Tribunal's finding that the inputs had not been received in the factory of the assessee and that the appeal could therefore be entertained under Section 35G.

Analysis: The Tribunal's conclusion rested on evidence, including the transport particulars and the official report showing that the vehicles mentioned in the invoices were not goods transport vehicles capable of carrying the stated consignments. The assessee failed to produce material to dislodge those findings. The High Court held that the controversy turned entirely on appreciation of evidence and recorded facts, and that it could not re-appreciate the evidence to take a different view in the absence of any substantial question of law.

Conclusion: No substantial question of law arose, and the appeal was liable to be dismissed.

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