Burden of proof for genuine dealer sales failed as factual findings defeated any substantial question of law.

The Delhi High Court found no substantial question of law in the Tribunal's order sustaining reassessment and penalty. The assessee had not produced credible evidence, such as bills, receipts, transport records or confirmations, to prove that the sales were made to genuine registered dealers or that the statutory declarations were authentic. The authorities concurrently found that the alleged purchasing dealers were non-existent or not registered and that the declarations were fake or unverified. Those conclusions were treated as factual findings based on the record, and no legal infirmity in the Tribunal's approach was shown.

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Issues: Whether any substantial question of law arose from the Tribunal's order sustaining reassessment and penalty, particularly on the genuineness of the statutory declarations and the alleged sales to registered dealers.

Analysis: The petition turned on findings that the assessee had failed to prove that the sales were made to genuine registered dealers and had not discharged the burden of producing credible documentary support such as bills, receipts, transport records, confirmations, or other evidence establishing the authenticity of the statutory forms. The authorities concurrently found that the alleged purchasing dealers were non-existent or not registered, that the declarations were fake or unverified, and that the assessee could not claim deduction unless the sales were proved to have been made to registered dealers. These were factual findings based on appreciation of material on record, and no legal infirmity or question of law was shown in the Tribunal's approach.

Conclusion: No substantial question of law arose, and the challenge to the reassessment and penalty could not be entertained.

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