Revisional interference for non-production of accounts upheld where later records were irrelevant to seized materials and suppression.

Revisional interference under the Tamil Nadu General Sales Tax Act was justified where the assessee, despite repeated opportunities, failed to produce books of account or explain seized materials. The later production of records did not cure the non-compliance because those documents were found irrelevant to the seized statements and records relied on by enforcement officials. On that basis, the revisional authority correctly treated the appellate relief as erroneous and restored the best judgment assessment and penalty.

---

---

Issues: Whether the revisional order under the Tamil Nadu General Sales Tax Act, 1959, restoring the best judgment assessment and penalty after the assessee failed to produce accounts despite repeated opportunities, was valid.

Analysis: The assessee was repeatedly summoned to produce books of account and to explain the seized materials, but failed to comply even after copies of the seized documents were furnished. The accident of one partner occurred after the relevant summons and did not explain the earlier non-compliance. The appellate authority's reliance on later-produced materials was found to be misplaced because those documents had no real relevance to the statement and records seized by the enforcement officials. In these circumstances, the revisional authority was justified in holding that the relief granted in appeal was erroneous and in restoring the assessment and penalty.

Conclusion: The revisional order was upheld and the challenge to it failed.

Final Conclusion: The writ appeal was dismissed, leaving the restored assessment and penalty intact.

Ratio Decidendi: Revisional interference is justified where an assessee, despite repeated opportunities, fails to produce accounts and the relief granted in appeal is based on materials found to be irrelevant to the seized records and admitted suppression.

---