Turnover estimation on factual findings raised no question of law, so revision under sales tax law was not entertainable.

Turnover estimated by the assessing authority on the basis of stock variation and excess stock of new gold ornaments was upheld by the appellate authority and Tribunal as reasonable. The challenge attacked only the factual appreciation behind that estimation and did not show any illegality in the method adopted. Because the concurrent finding rested on estimation of facts, no question of law arose for revision under section 41 of the Kerala General Sales Tax Act, 1963, and the revision petition was not entertainable.

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Issues: Whether the revision petition under section 41 of the Kerala General Sales Tax Act, 1963 could be entertained when the challenge was only to the Tribunal's affirmation of turnover estimated on facts.

Analysis: The turnover was estimated by the assessing authority at three times the average running stock because of stock variation, including excess stock of new gold ornaments. The appellate authority and the Tribunal upheld the assessment as reasonable. The challenge did not disclose any illegality in the method of estimation, and the matter turned on appreciation of facts. A finding resting on such estimation does not give rise to a question of law for revision under section 41.

Conclusion: The revision petition was not entertainable, as no question of law arose from the concurrent factual finding.

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