Acceptance of account books upheld where unentered vouchers and an unproved third-party letter did not justify rejection.

Properly maintained account books cannot be rejected merely because two purchase vouchers were not entered at the time of survey, where there is no finding that the transactions were never recorded later. An explanation that the purchases were made through the munim remained unrebutted, and a third-party letter alleging two sets of accounts could not be used against the assessee without proof of authorship or supporting evidence. The revising authority, as final fact-finder, was therefore entitled to accept the book version on the material before it, and its conclusion was not arbitrary or unsupported by evidence.

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Issues: Whether the revising authority was justified in accepting the dealer's account books despite the recovery of two unaccounted purchase vouchers and a third-party letter suggesting maintenance of two sets of accounts.

Analysis: The account books were found to have been properly maintained, and the mere fact that two bijaks were not entered at the time of survey was not sufficient, by itself, to justify rejection of the books. There was no finding that the transactions were never entered later. The explanation that the amounts related to purchases made through the munim was not displaced by any contrary material. The third-party letter could not be relied upon against the assessee in the absence of authorship or supporting evidence. As the revising authority was the final fact-finding authority, its acceptance of the book version could not be termed unsupported by material or arbitrary.

Conclusion: The revising authority was legally justified in accepting the account books, and the reference was answered in favour of the assessee.

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