pertaining to wrongful availment of credit or availment of inadmissible credit. However, the orders proceeded on the footing that the declaration under section 57G did not contain the reference to the finished products under Chapter 9306 and 3506. Rather they were withdrawn from the list of final products mentioned in the declaration. Thus, the allegations in the show cause notice, based and founded on which the orders should have been passed by the Commissioner and the Commissioner (Appeals), are not adhered to by them. They have traveled beyond the same and by referring to the declaration. If the credit was inadmissible and therefore wrongfully availed of, then, that was required to be reversed/recovered. That was the foundation on which the show cause notice was issued. That was the principal allegation. There was no reference therein to the declaration under Rule 57G or the deletion of the final product from the purview of the same. In such circumstances, the Tribunal rightly interfered with the concurrent orders and allowed the Assessee's Appeal. In any event, a declaration requiring the Assessee to mention the final product and which declaration is to be filled in, in compliance with the procedural provision, would not govern the issue of admissibility of the credit. That is how the Tribunal proceeds as well. On both counts, we do not find that its order is perverse or vitiated by error of law apparent on the face of the record. The substantial question of law would therefore
