Best judgment assessment based on stock variation and recovered slips sustained where factual findings showed suppressed turnover.

In a revision arising from best judgment assessment, stock variation and slips recovered during a surprise inspection were treated as evidence of suppressed turnover. The assessee's explanation for the stock discrepancy and the recovered slips was rejected by the appellate authority and the Sales Tax Appellate Tribunal, which was the final fact-finding authority. As the challenge turned entirely on appreciation of evidence and factual findings, and no substantial question of law arose, the High Court declined interference. The Tribunal's addition was therefore sustained and the revision petition was dismissed.

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Issues: Whether the addition made in the best judgment assessment on the basis of stock variation and recovered slips was justified.

Analysis: The stock discrepancy and the slips recovered during the surprise inspection were treated by the authorities as showing suppressed turnover. The explanation offered for the stock difference and for the slips was rejected by the appellate authority and the Sales Tax Appellate Tribunal, which acted as the final fact-finding authority. The challenge turned entirely on appreciation of evidence and findings on facts, and no substantial question of law arose.

Conclusion: The addition sustained by the Tribunal was upheld and the assessee's challenge failed.

Final Conclusion: The revision petition was dismissed as the Tribunal's decision rested on factual findings requiring no interference.

Ratio Decidendi: Where the final fact-finding authority has rejected the assessee's explanation for stock variation and suppressed sales evidenced by slips, interference is not called for in revision in the absence of a substantial question of law.

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