Escaped Turnover in Reassessment: minor stock-register discrepancies were held insufficient to disturb the factual finding

Minor discrepancies in a stock-transfer register were held insufficient to prove escaped turnover in reassessment, because the variations were negligible and no actual concealment of sales was shown. The Tribunal's finding that no turnover escapement had been established was based on appreciation of facts and evidence, and the revisional court found no ground to interfere with that factual conclusion. The finding was therefore upheld, and the revision was rejected against the Revenue.

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Issues: Whether the deletion of the estimated escaped turnover under reassessment called for interference in revision.

Analysis: The variations noticed in the stock-transfer register were found to be very minor and negligible. In view of the large assessed turnover and the absence of any actual concealment of sales, the conclusion was that no escapement of turnover had been established. The Tribunal's view rested on appreciation of facts and evidence, and the revisional court found no basis to disturb that factual finding.

Conclusion: The finding of no escapement of turnover was upheld and the revision was rejected against the Revenue.

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