Revisional interference cannot rest on suspicion alone when a reasoned appellate finding is supported by material evidence.

Revisional interference cannot rest on suspicion alone where the appellate authority has given a reasoned finding supported by material. The appellate authority accepted the assessee's documents and held that tax had been paid, and the absence of scrutiny marks on check-post documents did not, by itself, justify an adverse inference because it could also indicate waiver or negligence by the authorities. In the absence of cogent material or a better reasoned basis to displace that finding, the revisional authority was not justified in interfering. The appellate order was therefore upheld in favour of the assessee.

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Issues: Whether the revisional authority was justified in interfering with the appellate authority's order sustaining the assessee's documents and holding that the tax had been paid.

Analysis: The appellate authority had recorded a reasoned finding that the requisite documents established payment of tax and disclosed no illegality or irregularity. The mere fact that the check-post documents bore no indication of scrutiny could not, by itself, justify an adverse inference, since the absence of scrutiny could equally indicate waiver or negligence on the part of the authorities. Suspicion, without cogent and tangible material, was insufficient to upset the appellate finding. The revisional authority also failed to substitute the earlier well-reasoned order with a better or more persuasive one.

Conclusion: The revisional interference was unjustified and the appellate authority's order was upheld in favour of the assessee.

Ratio Decidendi: Revisional interference cannot be sustained on suspicion alone and is impermissible where a reasoned appellate order is supported by material and is not shown to be erroneous or inferior in reasoning.

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