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    <description>No interference was warranted where the Tribunal had found, on the record, no material showing fraud, collusion or intention to evade duty and had set aside the penalty. Those findings were treated as pure findings of fact, leaving no substantial question of law for consideration under the excise appeal provision. The respondent&#039;s status as a government undertaking also made an inference of duty evasion difficult on the facts found. The challenge was therefore declined at the threshold.</description>
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      <description>No interference was warranted where the Tribunal had found, on the record, no material showing fraud, collusion or intention to evade duty and had set aside the penalty. Those findings were treated as pure findings of fact, leaving no substantial question of law for consideration under the excise appeal provision. The respondent&#039;s status as a government undertaking also made an inference of duty evasion difficult on the facts found. The challenge was therefore declined at the threshold.</description>
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