Contention that 'Assessee was not service-provider but was service-recipient' is not 'a piece of evidence', it is a 'pleading, a ground of appeal' and goes to root of jurisdiction - Hence, same can be raised for first time before Commissioner (Appeals) Astron Polymers (P.) Ltd. Vs. Commissioner of Central Excise, Delhi-IV [(2014) 52 taxmann.com 372 […]
Contention that Assessee was service-recipient & not the provider cannot be termed as additional evidence
Contention that 'Assessee was not service-provider but was service-recipient' is not 'a piece of evidence', it is a 'pleading, a ground of appeal' and goes to root of jurisdiction – Hence, same can be raised for first time before Commissioner (Appeals)
Astron Polymers (P.) Ltd. Vs. Commissioner of Central Excise, Delhi-IV [(2014) 52 taxmann.com 372 (New Delhi – CESTAT)]
In the instant case, the Department demanded Service tax for the periods 2005-06 to 2007-08 on Rs. 14,40,000/- paid by Astron Polymers (P.) Ltd. (the Appellant) towards factory rent to one of its director. The Appellant denied liability to Service tax citing that levy was unconstitutional. However, the Appellant failed to submit that it was not a service provider, but was merely recipient of services from one of its directors.
The Department confirmed the demand along with interest and penalty. Against the Adjudication Order, the Appellant preferred an appeal before the Commissioner (Appeals) specifically contending that rent was being charged by Directors of the Appellant individually and not by the Appellant. The Commissioner (Appeals), relying upon Rule 5 of Central Excise (Appeals) Rules, 2001 (the Excise Appeal Rules), rejected the Appellant's contention on the ground that this was a new ground raised for the first time in the appeal and was not raised either in reply to the Show Cause Notice or during course of the Adjudication proceedings. Being aggrieved, the Appellant preferred an appeal before the Hon'ble CESTAT, Delhi.
The Hon'ble CESTAT, Delhi held that Rule 5 of the Excise Appeals Rules has no application in the instant case because a contention that the Appellant was not provider of service but was recipient of service is not 'a piece of evidence', it is a 'pleading, a ground of appeal' and goes to root of jurisdiction. Hence, such an additional ground is admissible and ought to be entertained and the Appellant must be called upon to substantiate this plea. Hence, the matter was remanded back for afresh adjudication.
It was further held by the Hon'ble High Court that there is difference between 'condonation of delay' and 'exclusion of period'. The condonation of delay is in the discretion of the Court or Forum, whereas exclusion of time under Section 14 of the Limitation Act is a mandate under law,without leaving any scope for subjectivity.
Time spent in pursuing remedy before wrong forum is excludible in determining period of limitation
Commissioner of Central Excise, Visakhapatnam-II Vs. Cairn Energy India Pvt. Ltd. [(2014) 52 taxmann.com 371 (High Court of Andhra Pradesh)]
Cairn Energy India Pvt. Ltd. (the Assessee) was engaged in manufacturer of Excisable goods, clearance of which required payment of Excise duty and cess. The Adjudication Authority vide its Order dated March 23, 2006, raised the demand of Excise duty amounting to Rs. 19,96,410/- along with interest under Section 11AB of the Central Excise Act, 1944. The copy of the said order was furnished to the Assessee on May 9, 2006 against which the Assessee filed an appeal before the Hon'ble Tribunal. The Hon'ble Tribunal vide its Order dated September 28, 2006 rejected the appeal on the ground that the appeal should have been filed before the Commissioner (Appeals).
Thereafter, the Assessee filed an appeal before the Commissioner (Appeals) on October 9, 2006 which was rejected on the ground of time barred. Being aggrieved, the Assessee filed an appeal before the Hon'ble Tribunal.
The Hon'ble Tribunal allowed the appeal in favour of the Assessee and held that the he was entitled to the benefit of Section 14 of the Limitation Act, 1963 (the Limitation Act) against which the Department filed an appeal before the Hon'ble High Court of Andhra Pradesh.
The Hon'ble High Court of Andhra Pradesh relied upon the following judgments of the Hon'ble Apex Court:
- Singh Enterprises CCE [(2008) 12 STT 21]
- CC&CE Hongo India (P.) Ltd. [2009 taxmann.com 547 (SC)] and
- Amchong Tea Estate Union of India [(2010) 1 taxmann.com 789 (SC)]
And held that in terms of Section 29 of Limitation Act, provisions of the Limitation Act are applicable, except when specifically excluded and as per Section 14 ibid, time spent in pursuing remedy bona fidely before wrong forum is excludible. It was further held by the Hon'ble High Court that there is difference between 'condonation of delay' and 'exclusion of period'. The condonation of delay is in the discretion of the Court or Forum, whereas exclusion of time under Section 14 of the Limitation Act is a mandate under law,without leaving any scope for subjectivity. Hence, the appeal filed before Commissioner (Appeals) was within time-limit.
Notification No. 19/2004-Central Excise (N.T.) Dated-6th September, 2004 In exercise of the powers conferred by rule 18 of the Central Excise Rules, 2002 and in supersession of the Ministry of Finance, Department of Revenue, notification No. 40/2001-Central Excise (NT), dated the 26th June 2001,[G.S.R.469(E), dated the 26thJune, 2001] in so far as it relates to […]
Notification No. 19/2004-Central Excise (N.T.), Dated-6th September, 2004
Notification No. 19/2004-Central Excise (N.T.)
Dated-6th September, 2004
In exercise of the powers conferred by rule 18 of the Central Excise Rules, 2002 and in supersession of the Ministry of Finance, Department of Revenue, notification No. 40/2001-Central Excise (NT), dated the 26th June 2001,[G.S.R.469(E), dated the 26thJune, 2001] in so far as it relates to export to the countries other than Nepal and Bhutan, the Central Government hereby directs that there shall be granted rebate of the wholeof the duty paid on all excisable goods falling under the First Schedule to the Central Excise Tariff Act, 1985 (5 of 1986), exported to any country other than Nepal and Bhutan, subject to the conditions, limitations and procedures specified hereinafter,-
(2) Conditions and limitations : -
(a) that the excisable goods shall be exported after payment of duty, directly from a factory or warehouse, except as otherwise permitted by the Central Board of Excise and Customs by a general or special order;
(b) the excisable goods shall be exported within six months from the date on which they were cleared for export from the factory of manufacture or warehouse or within such extended period as the Commissioner of Central Excise may in any particular case allow;
(c) that the excisable goods supplied as ship's stores for consumption on board a vessel bound for any foreign port are in such quantities as the Commissioner of Customs at the port of shipment may consider reasonable;
(d) the rebate claim by filing electronic declaration shall be allowed from such place of export and such date, as may be specified by the Board in this behalf;
(e) that the market price of the excisable goods at the time of exportation is not less than the amount of rebate of duty claimed;
(f) that the amount of rebate of duty admissible is not less than five hundred rupees;
(g) that the rebate of duty paid on those excisable goods, export of which is prohibited under any law for the time being in force, shall not be made.
(3) Procedures:-
(a) Sealing of Goods and examination at the place of dispatch and export:-
(i) The manufacturer exporters registered under the Central Excise Rules, 2002 and merchant-exporters who procure and export the goods directly from the factory or warehouse can exercise the option of exporting the goods sealed at the place of dispatch by a Central Excise Officer or under self-sealing;
(ii) Where the exporter desires self-sealing and self-certification, the manufacturer of the export goods or owner of the warehouse shall take the responsibility of sealing and certification;
(iii) The merchant-exporters other than those procuring the goods directly from the factory or warehouse shall export the goods sealed at the place of dispatch by a Central Excise Officer;
(iv) For the sealing of goods intended for export, at the place of dispatch, the exporter shall present the goods along with four copies of application in the Form ARE-I specified in the Annexure to this notification to the Superintendent or Inspector of Central Excise having jurisdiction over the factory of production or manufacture or warehouse;
(v) The said Superintendent or Inspector of Central Excise shall verify the identity of goods mentioned in the application and the particulars of the duty paid or payable, and if found in order, shall seal each package or the container in the manner as may be specified by the Commissioner of Central Excise and endorse each copy of the application in token of having such examination done;
(vi) The said Superintendent or Inspector of Central Excise shall return the original and duplicate copies of application to the exporter;
(vii) The triplicate copy of application shall be -
(a) sent to the officer with whom rebate claim is to be filed, either by post or by handing over to the exporter in a tamper proof sealed cover after posting the particulars in official records, or
(b) sent to the Excise Rebate Audit Section at the place of export in case rebate is to be claimed by electronic declaration on Electronic Data Inter-change system of Customs;
(viii) The exporter may prepare quadruplicate copy of application for claiming any other export incentive. This copy shall be dealt in the same manner as the original copy of application;
(ix) Where goods are not exported directly from the factory of manufacture or warehouse, the triplicate copy of application shall be sent by the Superintendent having jurisdiction over the factory of manufacture or warehouse, who shall, after verification, forward the triplicate copy in the manner specified in sub-paragraph (vii);
(x) In case of export by parcel post after the goods intended for export have been sealed, the exporter shall affix to the duplicate application sufficient postage stamps to cover postal charges and shall present the documents, together with the package or packages to which it refers, to the postmaster at the office of booking;
(xi) Where the exporter desires self-sealing and self-certification for removal of goods from the factory or warehouse or any approved premises, the owner, the working partner, the Managing Director or the Company Secretary, of the manufacturing unit of the goods or the owner of warehouse or a person duly authorized by such owner, working partner or the Board of Directors of such Company, as the case may be, shall certify on all the copies of the application that the goods have been sealed in his presence, and shall send the original and duplicate copies of the application along with the goods at the place of export, and shall send the triplicate and quadruplicate copies of the application to the Superintendent or Inspector of Central Excise having jurisdiction over the factory or warehouse within twenty four hours of removal of the goods;
(xii) In case of self-sealing, the said Superintendent or Inspector of Central Excise shall, after verifying the particulars of the duty paid or duty payable and endorsing the correctness or otherwise, of these particulars-
(a) send to the officer with whom rebate claim is to be filed, either by post or by handing over to the exporter in a tamper proof sealed cover after posting the particulars in official records, or
(b) send to the Excise Rebate Audit Section at the place of export in case rebate is to be claimed by electronic declaration on Electronic Data Inter-change system of Customs;
(xiii) On arrival at the place of export, the goods shall be presented together with original, duplicate and quadruplicate (optional) copies of the application to the Commissioner of Customs or other duly appointed officer;
(xiv) The Commissioner of Customs or other duly appointed officer shall examine the consignments with the particulars as cited in the application and if he finds that the same are correct and exportable in accordance with the laws for the time being in force, shall allow export thereof and certify on the copies of the application that the goods have been duly exported citing the shipping bill number and date and other particulars of export:
Provided that if the Superintendent or Inspector of Central Excise sealed packages or container at the place of dispatch, the officer of customs shall inspect the packages or container with reference to declarations in the application to satisfy himself about the exportability thereof and if the seals are found intact, he shall allow export.
(xv) The officer of customs shall return the original and quadruplicate (optional copy for exporter) copies of application to the exporter and forward the duplicate copy of application either by post or by handing over to the exporter in a tamper proof sealed cover to the officer specified in the application, from whom the exporter wants to claim rebate:
Provided that where the exporter claims rebate by electronic declaration on the Electronic Data Inter-change system of Customs, the duplicate shall be sent to the Excise Rebate Audit Section at the place of export.
(xvi) The exporter shall use the quadruplicate copy for the purposes of claiming any other export incentive.
(b) Presentation of claim for rebate to Central Excise:-
(i) Claim of the rebate of duty paid on all excisable goods shall be lodged along with original copy of the application to the Assistant Commissioner of Central Excise or the Deputy Commissioner of Central Excise having jurisdiction over the factory of manufacture or warehouse or, as the case may be, the Maritime Commissioner;
(ii) The Assistant Commissioner of Central Excise or the Deputy Commissioner of Central Excise of Central Excise having jurisdiction over the factory of manufacture or warehouse or, as the case may be, Maritime Commissioner of Central Excise shall compare the duplicate copy of application received from the officer of customs with the original copy received from the exporter and with the triplicate copy received from the Central Excise Officer and if satisfied that the claim is in order, he shall sanction the rebate either in whole or in part.
(c) Claim of rebate by electronic declaration:-An exporter may enter the requisite information in the shipping bill filed at such place of export, as may be specified by the Board, for claiming rebate by electronic declaration on Electronic Data Inter-change system of Customs. The details of the corresponding application shall be entered in the Electronic Data Inter-change system of Customs upon arrival of the goods in the Customs area. After goods are exported or order under section 51 of the Customs Act, 1962 (52 of 1962) has been issued, the rebate of excise duty shall, if the claim is found in order, be sanctioned and disbursed by the Assistant Commissioner of Customs or the Deputy Commissioner of Customs.
(d) Special procedure for store for consumption on board an aircraft on foreign run:- Notwithstanding anything contained in the above paragraphs, in case of mineral oil products falling under Chapter 27 of the First Schedule to the Central Excise Act, 1985 (5 of 1986) exported as stores for consumption on board an aircraft on foreign run, the rebate shall be granted for such quantity of the products as remain on board the aircraft after completion of an internal flight but prior to its reversion to foreign run. The concerned officer of Customs shall certify in the manner specified by the Commissioner of Central Excise the quantity of products left on board for determining the quantum of rebate.
(e) Cancellation of documents:- If the excisable goods are not exported, the Assistant Commissioner of Central Excise or the Deputy Commissioner of Central Excise shall cancel the export documents.
Explanation I – "duty" for the purpose of this notification means duties of excise collected under the following enactments, namely:
(a) the Central Excise Act, 1944 (1 of 1944);
(b) the Additional Duties of Excise (Goods of Special Importance) Act, 1957 (58 of 1957);
(c) the Additional Duties of Excise (Textiles and Textile Articles) Act, 1978 (40 of 1978);
( d ) the National Calamity Contingent duty leviable under section 136 of the Finance Act, 2001 (14 of 2001), as amended by section 169 of the Finance Act, 2003 (32 of 2003) and further amended by section 3 of the Finance Act, 2004 (13 of 2004);
(e) special excise duty collected under a Finance Act;
(f) additional duty of excise as levied under section 157 of the Finance Act, 2003 (32 of 2003);
(g) Education Cess on excisable goods as levied under clause 81 read with clause 83 of the Finance (No.2) Bill, 2004.
Explanation II – For the purpose of this notification, the expression 'electronic declaration" means the declaration of the particulars relating to the export goods, lodged in the Customs Computer System, through the data-entry facility provided at the Service Center or the data communication networking facility provided by the Indian Customs and Central Excise Gateway (called ICEGATE), from the computer of the person authorized for this purpose.
Explanation III – For the purposes of this notification, "Maritime Commissioner" means the Commissioner of Central Excise under whose jurisdiction one or more of the port, airport, land customs station or post office of exportation, is located.
Annexure
Range………..
Division…………..Address…………………
Commissionerate………………..
Original (White)/Duplicate (Buff)
Triplicate (Pink)/Quadruplicate (Green)
Triplicate (Pink)/Quadruplicate (Green)
FORM A.R.E. 1
Application for removal of excisable goods for export by (Air/Sea/Post/Land)*
To
Superintendent of Central Excise
……………………(Full Postal Address)
1. Particulars of Assistant/Deputy Commissioner of Central Excise]/Maritime Commissioner of Central Excise from whom rebate shall be claimed/with whom bond/undertaking is executed and his complete postal address.
2. I/ We …….. of …………..propose to export the under-mentioned consignment to ……….. (Country of destination) by Air/ Sea/ Land/ Parcel Post under claim for rebate/ bond/ undertaking*.
Particulars of Manufacturer of goods and his Central Excise Registration No | No. and Description of packages | Gross weight/ Net weight | Marks and Nos. on packages | Quantity of goods | Description of goods | Value | Duty | No. and date of Invoice under which duty was paid/No. and date of bond/undertaking executed under rule 19 | Amount of Rebate claimed | Remarks | |
| | | | | | | | Rate | Amount (Rs.) | | | |
| (1) | (2) | (3) | (4) | (5) | (6) | (7) | (8) | (9) | (10) | (11) | (12) |
- I/We hereby certify that the above- mentioned goods have been manufactured.
(a) availing facility/without availing facility of CENVAT credit under CENVAT Credit Rules, 2002
(b) availing facility/without availing facility under Notification No.21/2004-Central Excise (N.T.), dated the 6th September, 2004 issued under rule 18 of Central Excise Rules, 2002.
(c) availing facility/without availing facility under Notification No.43/2001-Central Excise (N.T.), dated the 26th June, 2001 issued under rule 19 of Central Excise (No.2) Rules, 2001.
- I/We hereby declare that the export is in discharge of the export obligation under a Quantity based Advance License/Under Claim of Duty Drawback under Customs and Central Excise Duties Drawback Rules, 1995.
- I/We hereby declare that the above particulars are true and correctly stated.
Time of Removal…………………………….
Signature of owner or his
Authorised agent with date.
Name in Block Letters and Designation (SEAL)
Authorised agent with date.
Name in Block Letters and Designation (SEAL)
PART A
Certification by Central Excise Officer
- Certified that duty has been paid by debit entry in the Personal Ledger Account No. ………and/or CENVAT Account Entry No..……or recorded as payable in Daily Stock Account, on the goods described overleaf.
OR
Certified that the owner has entered into Bond No. ………… under Rule 19 of Central Excise Rules, 2002 with the……………………………….[F.No.___________________], duly accepted by the Assistant Commissioner/Deputy Commissioner of Central Excise________ on _________(Date).
- Certified that I have opened and examined the packages No…..…………………………………………………… and found that the particulars stated and the description of goods given overleaf and the packing list (if any) are correct and that all the packages have been stuffed in the container No. …………… with Marks ……………… and the same has been sealed with Central Excise Seal/One Time Seal (OTS) No. ………….
- I have verified with the records, the exporter is only availing the export incentives, as specified in box No.6 and found it to be true.
- Certified that I have drawn three representative samples from the consignment (wherever necessary) and have handed over, two sets thereof duly sealed to the exporter/his authorised representative.
Place…………………
Date ……………………
| Signature | Signature |
| (Name in Block Letters) | (Name in Block Letters) |
| Superintendent of Central Excise | Inspector of Central Excise |
PART B
CERTIFICATION BY THE OFFICER OF CUSTOMS
Certified that the consignment was shipped under my supervision under Shipping Bill No_______ dated _______by S.S./Flight No. ______which left on the_______ day of________ (Month )_ _________(year)
OR
Certified that the above-mentioned consignment was stuffed in Container No._____________________ belonging to Shipping Line_________________ based on the "Let Export Order" given on ____________day of.________(Month)__________year) on the Shipping Bill No______ dated________ and sealed by seal/one time lock No._______________ in my supervision and the container was handed over to the Custodian M/s______________ for being shipped via ___________________(Name of the Port).
OR
Certified that the above-mentioned consignment has been duly identified and has passed the land frontier today at_______in its original condition under Bill of Exports No______________ Place_____________ Date_____________.
Signature
(Name and designation of the Officer of Customs
in Block Letters)/(Seal)
in Block Letters)/(Seal)
PART C
EXPORT BY POST
Certified that the consignment described overleaf has been dispatched by foreign post to ……………………… on ……………….. day of 200……….
Place ………..
Date ……….
Signature of Post Master with seal
PART D
REBATE SANCTION ORDER
(On Original, Duplicate and Triplicate)
Refund Order No……………….. dated ………………….. Rebate of Rs…………….. (Rupees ……………..) sanctioned vide Cheque No. ………………dated …………………
Place ………..
Date ……….
Assistant/Deputy Commissioner/ Maritime
Commissioner of Central Excise
Commissioner of Central Excise
*Strike out inapplicable portions.
F.No. 209/24/2003-CX.6
Neerav Kumar Mallick
Under Secretary to the Government of India
Under Secretary to the Government of India
Supply of aviation fuel to foreign going aircraft from fuelling Station registered as warehouse is eligible for rebate Indian Oil Corporation Ltd. Vs. Union of India [(2014) 52 taxmann.com 294 (High Court of Bombay)] Indian Oil Corporation Ltd. (the Petitioner) had procured Aviation Turbine Fuel (ATF or the fuel) from the refinery of Bharat Petroleum […]
Rebate on Supply of aviation fuel to foreign going aircraft from fuelling Station registered as warehouse
Supply of aviation fuel to foreign going aircraft from fuelling Station registered as warehouse is eligible for rebate
Indian Oil Corporation Ltd. Vs. Union of India [(2014) 52 taxmann.com 294 (High Court of Bombay)]
Indian Oil Corporation Ltd. (the Petitioner) had procured Aviation Turbine Fuel (ATF or the fuel) from the refinery of Bharat Petroleum Corporation Ltd (BPCL) on payment of Excise duty. The fuel was initially stored at the terminal and thereafter it was sold at NITC, IGI Airport, Delhi. A part quantity of ATF purchased from the BPCL was for supply to the foreign going aircraft. The safety requirements and lack of space at airport permits storage facility to BPCL at IGI Airport, New Delhi.
In this case, ATF was purchased from BPCL and part of it was sold to BPCL itself. The other part of ATF acquired from BPCL was sold to foreign going aircraft. The Petitioner obtained a joint certificate and thereafter proceeded to lodge a claim for refund of Rs. 10,93,745/- under Rule 18 of the Central Excise Rules, 2002, being the duty paid on ATF supplied to foreign going aircraft, from NITC, IGI Airport, Delhi, Aviation Fuelling Station, Delhi (AFS).
However, the refund claim was rejected on the ground that export was not directly from factory/ warehouse violating condition in Para 2(a) of the Notification No. 19/2004-CE (NT) dated September 6, 2004 (the Notification). On appeal being filed to the Commissioner of Central Excise (Appeals), the same was dismissed on June 21, 2006.
Thereafter, a Revision Application was filed before the Joint Secretary to the Government of India which has been rejected vide the Order November 11, 2009. Being aggrieved, the Petitioner filed a Writ Petition before the Hon'ble High Court of Bombay.
The Hon'ble High Court held as under:
- The Petitioner had supplied the fuel to aircrafts on foreign run by transferring duty paid products to the AFS (Mumbai-Delhi) which has been registered as a warehouse of Excisable goods. Hence, condition in Para 2(a) of the Notification is satisfied;
- Since the Excisable goods are exported after payment of duty directly from a factory or warehouse, then nothing more is required to be considered and verified;
- The Department had not produced any document, which superseded the Notification or modifies or amends the same in any manner;
Commissioner of Central Excise Vs. Koya & Company Construction (Pvt.) Ltd. [(2014) 52 taxmann.com 342 (SC)] Koya & Company Construction Pvt. Ltd. (the Assessee) was engaged in the manufacture and selling of PSC pipes. The Assessee cleared the PSC pipes on payment of Excise duty to KCCL, an interconnected undertaking. The duty liability was calculated […]
No appeal would lie before Supreme Court on factual findings of Tribunal
Commissioner of Central Excise Vs. Koya & Company Construction (Pvt.) Ltd. [(2014) 52 taxmann.com 342 (SC)]
Koya & Company Construction Pvt. Ltd. (the Assessee) was engaged in the manufacture and selling of PSC pipes. The Assessee cleared the PSC pipes on payment of Excise duty to KCCL, an interconnected undertaking. The duty liability was calculated on Transaction Value in respect of clearance made to an interconnected undertaking.
The Department argued that since there was 'mutuality of interest' as the Assessee had received interest-free advance of Rs. 7.2 crores from his inter connected undertaking, therefore the Assessable Value was to be determined as per Rule 9 of the Central Excise Valuation (Determination of Price of Excisable Goods) Rules 2000 (the Valuation Rules)
The Assessee filed an appeal before the Hon'ble Tribunal arguing that:
- Interest-free advance was a commercial transaction, which was reduced from Rs. 7.2 crores on March 31, 2003 to Rs. 24 lakhs on March 31, 2004; and
- Since, the Assessee and his inter connect undertaking were not under
Holding and Subsidiary relationship, Rule 10 of the Valuation Rules was also inapplicable
Accordingly, the Hon'ble Tribunal held that:
- The advance had been decreased on account of supply of goods by the Assessee to buyer; therefore, it was a commercial transaction and there was no 'mutuality of interest';
- In absence of relationship as defined under Sections 4(3)(b)(ii)/(iii)/(iv) of the Central Excise Act, 1944, Rule 9 of the Valuation Rules or proviso thereto was not applicable;
- Rule 10(b) of the Valuation Rules would not be applicable because there is no Holding – Subsidiary relationship between the Assessee and his buyer of the goods.
- Accordingly, Assessable Value would be determined as per Rule 11 of the Valuation Rules i.e. best judgment and value will be determined just like captive consumption under Rule 8 of the Valuation Rules.
Being aggrieved, the Department filed an appeal before the Hon'ble Apex Court.
The Hon'ble Apex Court after observing that the Tribunal had passed the order on the basis of facts and circumstance of the case, held that since the Tribunal is the final fact finding authority, no appeal would lie before the Supreme Court on such factual findings.
__._,_.___
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