Question of law threshold bars reference where dispute turns on appreciation of evidence and factual findings.

Reference under Section 35G lies only on a genuine question of law, not on mere disagreement with the Tribunal's appreciation of evidence. Challenges directed at witness statements, corroborative documents, the probative value of records, and alleged shifting of the burden of proof remained factual in nature because the Tribunal had considered the material, given reasons, and reached its conclusion on the totality of circumstances. No referable question of law arose, so the reference application was not maintainable on the grounds urged.

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Issues: Whether the applicants had shown any question of law arising from the Tribunal's order so as to warrant a reference to the High Court under Section 35G of the Central Excises and Salt Act.

Analysis: Reference under Section 35G lies only on a question of law. The grounds urged by the applicants related essentially to appreciation of evidence, evaluation of witness statements, treatment of corroborative documents, the probative value of the SASMIRA certificate, the Octroi letter, the "Crystal Picture" notebook, and the alleged shifting of burden of proof. The Tribunal had considered the material on record, assigned reasons for accepting and rejecting the evidence, and reached a conclusion based on the totality of circumstances. Mere disagreement with that appreciation, or the possibility of another view on facts, did not convert the dispute into a referable question of law.

Conclusion: No referable question of law arose. The application for reference was not maintainable on the grounds urged and failed.

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