Sales tax exemption must be proved by reliable evidence; no interference was warranted where opportunity and record support were found.

Adequate opportunity was held to have been given where the assessee received the show cause notice but filed no objections or request for extension, so no procedural unfairness justified interference in revision. The claim for sales tax exemption on disputed turnover also failed because the purchase bills did not show the sarees were handloom goods and no clinching evidence was produced before the appellate authorities or Tribunal. The revisional court found the Tribunal's conclusions supported by the record and declined to interfere, leaving the tax liability intact.

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Issues: (i) Whether the assessee was denied sufficient opportunity before the authorities below; (ii) Whether the assessee proved that the disputed turnover related to handloom silk sarees entitled to exemption from sales tax.

Issue (i): Whether the assessee was denied sufficient opportunity before the authorities below.

Analysis: The record showed that the assessee received the show cause notice but did not file objections or seek extension of time. On that basis, the Tribunal found that adequate opportunity had been afforded. No material showed procedural unfairness requiring interference in revision.

Conclusion: The issue was decided against the assessee.

Issue (ii): Whether the assessee proved that the disputed turnover related to handloom silk sarees entitled to exemption from sales tax.

Analysis: The purchase bills did not indicate that the sarees were handloom sarees, and no clinching evidence was produced before the appellate authorities or the Tribunal to establish the exemption claim. The finding of the Tribunal was therefore supported by the material on record.

Conclusion: The issue was decided against the assessee.

Final Conclusion: The revisional court found no illegality in the Tribunal's findings and declined to interfere, leaving the tax liability intact.

Ratio Decidendi: A claim for sales tax exemption must be established by reliable evidence, and revisional interference is unwarranted where the Tribunal's findings are supported by the record and no procedural unfairness is shown.

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