JUDGMENT PRAKASH KRISHNA, J. - The dispute in the present revision relates to the assessment year 1986-87 under the U.P. Sales Tax Act, 1948. The applicant is carrying on the business of manufacture and sales of paraffin wax, foot oil and its by-products, etc. The dispute relates about taxability of turnover of Rs. 9,61,602.14. The contention of the applicant was that it made sales of paraffin wax, foot oil to M/s. Suman Kutir Udyog who was a recognition certificate holder and it had issued form IIIB. The said form IIIB authorises exemption from or concessional rate of tax. The said contention has not been accepted by all the three authorities below. They have found that there is no firm registered with the Department known as Suman Kutir Udyog. In the memo of revision, the following questions of law have been sought to be raised : (i) Whether, on the facts and circumstances of the case, the Sales Tax Tribunal was justified in law in confirming the orders passed by the courts below ? (ii) Whether, on the facts and circumstances of the case, the Sales Tax Tribunal was legally justified in law in fixing the liability of tax upon the applicant against form IIIB duly issued by the purchasing dealer ? (iii) Whether, on the facts and circumstances of he case, the Sale Tax Tribunal was legally justified in law in determining the turnover of the selling dealer (applicant) against sales made through form IIIB ? (iv) Whether, on the facts and circumstances of the case, the Sales Tax Tribunal was legally justified in law in fixing the obligations on the selling dealer to enquire as to the correctness of the declaration ? (v) Whether, on the facts and circumstances of the case, the Sales Tax Tribunal was legally justified in law in ignoring the relevant papers filed by the applicant at the time of hearing in respect of the sale made against form IIIB ? (vi) Whether in any view of the matter the Sales Tax Tribunal was legally justified in law in fixing the tax liability against the applicant under section 4B ? Shri Ashok Kumar, learned counsel for the dealer - applicant, submits only this much that the authorities below were not justified in not extending the benefit of form IIIB which was issued by Suman Kutir Udyog. Shri Ashok Kumar, learned counsel for the dealer - applicant, submits only this much that the authorities below were not justified in not extending the benefit of form IIIB which was issued by Suman Kutir Udyog. The form IIIB was issued by the Department and there is no dispute that the said form is not genuine one. M/s. Suman Kutir Udyog approached the dealer - applicant and on the basis of the registration certificate produced by it, the dealer entered into transaction of sale with it and obtained form IIIB for charging concessional rate of tax. The learned standing counsel on the other hand submits that it has been found by all the authorities below that Suman Kutir Udyog is a non-existent firm. The alleged recognition certificate was never issued by the Department to Suman Kutir Udyog. The said purchasing dealer is also not registered with the Department. The form IIIB bearing No. 173232 was issued by the Sales Tax Officer to Aligarh Ispat Udyog but not to Suman Kutir Udyog. The findings recorded by the Tribunal are findings of fact, submits the learned standing counsel. Considered the respective submissions of the learned counsel for the parties and perused the record. The matter was heard on various occasions. This court had earlier directed the learned standing counsel to produce the record pertaining to issuance of form IIIB bearing No. 173232. An affidavit has been filed by Shri Uday Bhan Yadav, Assistant Commissioner, Section 1, Aligarh stating that Aligarh Ispat Udyog is not traceable as it has closed down his business. All the three authorities below have found that Suman Kutir Udyog is a non-existing firm nor was it registered with the Sales Tax Department. It has been further found that the form IIIB in question was issued to Aligarh Ispat Udyog. The Tribunal has recorded a finding that the dealer could not produce any evidence to show that any sale transaction took place at the hand of the dealer. It could not explain the manner in which the goods were despatched from Allahabad to Aligarh. The only explanation which was submitted by the dealer - applicant was that the purchaser took the delivery of goods at his shop and payment was made to him but the same has not been accepted. It could not explain the manner in which the goods were despatched from Allahabad to Aligarh. The only explanation which was submitted by the dealer - applicant was that the purchaser took the delivery of goods at his shop and payment was made to him but the same has not been accepted. It has further found that the dealers received various bank drafts, the details of which have been noted in the order of the Tribunal. In view of the finding recorded by the Tribunal that the alleged sale by the dealer - applicant is suspicious and not beyond doubt, the authorities below were justified in refusing to extend any benefit of form IIIB to the dealer - applicant. When a transaction itself is surrounded by suspicious circumstances, as has been found in the present case, a person cannot take the shelter that the purchasing dealer had issued form IIIB. It is incumbent upon the person who is claiming exemption/concessional rate of tax on a transaction, to prove the transaction with reasonable certainty. The findings recorded by the Tribunal are basically findings of fat and they do no suffer from any error of law. The apex court in Rashtriya Audyogik Sansthan v. Commissioner of Trade Tax, U.P. [2007] 6 VST 763 (SC); [2007] UPTC 547, Commissioner of Sales Tax, U.P. v. Mohan Brickfield [2006] 148 STC 638 (SC); [2007] 1 UPTC 1 (SC) and Commissioner of Sales Tax v. Kumaon Tractors & Motors [2002] 9 SCC 379 has held that section 11 of the Trade Tax Act confers a limited jurisdiction to interfere with the order of the Tribunal only on the question of laws, that too the said question of law is required to be precisely framed or formulated. The learned counsel for the dealer - applicant could not point out any illegality or perversity in the findings recorded by the Tribunal. He just impressed upon the court to re-appreciate the material which is not permissible under section 11 of the Act. There is no merit in the revision. The revision is dismissed but no order as to costs.