Stock suppression supports reassessment, equal-time addition, and penalty where inspection and account records reveal deliberate inconsistency.

Reassessment based on detected stock variation and suppression of opening stock is sustainable when supported by fresh material from inspection and account verification, rather than a mere change of opinion. Where suppression of stock and turnover is established, equal-time addition may be made on the same factual basis. Penalty under section 16 of the Tamil Nadu General Sales Tax Act, 1959 is also supportable when the record shows deliberate suppression through inconsistent opening stock figures, not a bona fide accounting error. The commentary therefore affirms that reassessment, best judgment-style addition, and statutory penalty can all stand on proof of suppression.

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Issues: (i) Whether the reassessment based on stock variation and alleged suppression of opening stock was sustainable; (ii) whether equal-time addition was warranted; (iii) whether penalty under section 16 of the Tamil Nadu General Sales Tax Act, 1959 was liable to be interfered with.

Issue (i): Whether the reassessment based on stock variation and alleged suppression of opening stock was sustainable.

Analysis: The stock discrepancy was not treated as a mere arithmetical mismatch. The accounts disclosed two different opening stock figures at different stages, and the variation detected in inspection was supported by the subsequent check of accounts. On those facts, the reassessment was founded on fresh material and not on a mere change of opinion. The finding of suppression was based on record and was not shown to be perverse.

Conclusion: The reassessment was valid and the finding of suppression was upheld, in favour of the Revenue.

Issue (ii): Whether equal-time addition was warranted.

Analysis: Once suppression of stock and turnover was established, equal-time addition could be made on the same factual basis. The Court found no legal infirmity in applying the settled principle that such addition is justified where suppression is proved.

Conclusion: Equal-time addition was upheld, in favour of the Revenue.

Issue (iii): Whether penalty under section 16 of the Tamil Nadu General Sales Tax Act, 1959 was liable to be interfered with.

Analysis: The levy of penalty was sustained because the case involved deliberate suppression by furnishing different opening stock figures, and not a mere difference of opinion or bona fide accounting error. In that setting, the statutory penalty was held to be neither excessive nor without jurisdiction.

Conclusion: The penalty was upheld, in favour of the Revenue.

Final Conclusion: The writ petition failed in full, and the assessment, equal-time addition, and penalty were all left undisturbed.

Ratio Decidendi: Reassessment based on fresh material showing suppression is not vitiated as a mere change of opinion, and once suppression is established, best judgment additions and statutory penalty are sustainable.

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