Concurrent findings on no manufacturing activity and valid account books will not be disturbed in revision absent a substantial question of law.

Concurrent findings that the dealer had not installed machinery or equipment to process crude mentha oil into a different product were upheld, as the material showed only a difference in strength between purchase and export documents and not manufacture of a new product. The Tribunal's acceptance of the account books was also sustained because the seized documents were verifiable from the dealer's own records, making their rejection unsustainable. As no infirmity was shown in these factual findings and no substantial question of law arose, revisionary interference was declined and the assessee's success before the Tribunal remained undisturbed.

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Issues: Whether the Tribunal was justified in accepting the dealer's account books and in holding that no manufacturing activity had been undertaken so as to warrant interference in revision.

Analysis: The appellate authorities had concurrently found that the dealer had not installed machinery or equipment at its premises to process the crude mentha oil into a different product. The difference in strength shown in purchase documents and export documents, by itself, was held insufficient to establish that a new product had been manufactured. The Tribunal also found that the goods remained crude mentha oil and that the rejection of account books on the basis of seized documents was unsustainable because those documents were verifiable from the dealer's own records. No infirmity was shown in these factual findings, and no substantial question of law arose for revisionary interference.

Conclusion: The Tribunal's acceptance of the account books and its finding that no manufacturing activity was proved were upheld, and interference was declined.

Final Conclusion: The revision was without merit and stood dismissed, leaving the assessee's success before the Tribunal undisturbed.

Ratio Decidendi: Concurrent findings of fact on absence of manufacturing activity and on the correctness of account books will not be interfered with in revision unless they disclose a substantial question of law.

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