Suppression findings need adequate material, and turnover estimates should not be reversed without cogent reasons.

A finding of suppression cannot rest on a single inspection and isolated stock variation; without further material, a pattern of suppression is not established. The first appellate authority's reduction of the turnover estimate to three times the suppressed turnover was a factual assessment that should not be reversed in appeal without cogent reasons. The Tribunal's contrary view was unsupported by the record, so the interference with the estimate of turnover was not justified.

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Issues: Whether a pattern of suppression could be inferred from a single inspection and whether the Appellate Tribunal was justified in reversing the first appellate authority's estimate of turnover.

Analysis: The stock variation was noticed on only one date and no further inspection was made. On those facts, a pattern of suppression could not be established. The first appellate authority had reduced the estimate to three times of the suppressed turnover, and such a finding ought not to have been reversed without cogent reasons. The Tribunal's contrary view was unsupported by the facts on record.

Conclusion: The pattern of suppression was not established, and the Tribunal was not justified in interfering with the first appellate authority's estimate of turnover.

Ratio Decidendi: A finding of suppression must rest on adequate material, and an appellate order reducing the estimate of turnover cannot be reversed lightly without cogent reasons.

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