Rejection of books of account upheld where power consumption, missing records, and job-work discrepancies showed suppression of turnover.

Higher electricity consumption, declining production figures, and non-production of the production register, wage records, labour attendance records, and material-wise job-work accounts justified rejection of the books of account. The Tribunal, as final fact-finding authority, relied on these surrounding circumstances to infer suppression of production and turnover. The assessee's explanation for the change in product thickness and the alleged continued operation of the chilling plant during closure was rejected on the facts. The rejection of the books and estimation of turnover were upheld as sustained findings of fact not liable to interference.

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Issues: Whether the rejection of the assessee's books of account and the estimate of turnover on the basis of higher electricity consumption, non-production of relevant records, and other surrounding circumstances was justified.

Analysis: The assessee's electricity consumption increased while production figures showed a decline over the relevant assessment years. The authorities also found that the production register, wage records, labour attendance records, and material-wise job-work accounts were not produced for verification despite opportunities. The explanation that the unit had shifted from 23 micron to 12 micron goods and that the chilling plant continued to run during closure was not accepted on the facts. The Tribunal, as the final fact-finding authority, relied on several material circumstances, including the mismatch between consumption and production, non-verification of job-work, and absence of reliable supporting records, to infer suppression of production and turnover.

Conclusion: The rejection of the books of account and the estimation of turnover were upheld, and the challenge to those factual findings failed.

Ratio Decidendi: Where the fact-finding authority records multiple supporting reasons, including abnormal power consumption, non-production of relevant records, and lack of verification of job-work and wage data, the resulting finding of suppression of production and turnover is ordinarily a sustained finding of fact not liable to interference.

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