Revisional interference limits in tax assessment matters depend on questions of law, not concurrent factual findings.

Third-party material used in assessment should ordinarily be disclosed, and where adverse unnumbered bills are relied on, inspection and, if required, cross-examination should be afforded to meet the material fairly. Rejection of account books and best judgment estimation of turnover are primarily factual matters. Revisional interference under the Trade Tax Act is limited to cases involving a question of law, illegality, or perversity; concurrent findings of fact by the assessment, appellate, and tribunal authorities were treated as insufficient for interference.

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Issues: (i) Whether the rejection of the books of account and the best judgment assessment could be interfered with on the ground that the assessee was not supplied copies of the unnumbered bills and was denied cross-examination of the person who furnished them; (ii) Whether, in the absence of any question of law and in the presence of concurrent findings of fact, revisional interference was warranted.

Issue (i): Whether the rejection of the books of account and the best judgment assessment could be interfered with on the ground that the assessee was not supplied copies of the unnumbered bills and was denied cross-examination of the person who furnished them.

Analysis: The material relied upon against an assessee must ordinarily be disclosed, and where third-party material is used, an opportunity of inspection and, where required, cross-examination should be afforded. On the facts, the assessment authorities had relied upon material said to be adverse to the assessee, and the challenge was that the assessee had not been given a fair opportunity to meet that material. Such denial, if established, would offend the requirements of fair hearing.

Conclusion: The contention was accepted only to the extent that the matter required reconsideration at the assessment stage, but no final relief on merits of the turnover was granted in the revision itself.

Issue (ii): Whether, in the absence of any question of law and in the presence of concurrent findings of fact, revisional interference was warranted.

Analysis: Rejection of account books and estimation of turnover are essentially factual determinations. The assessment, appellate, and tribunal authorities had returned concurrent findings that the books were not properly maintained and that the assessee had not successfully rebutted the adverse material. In revisional jurisdiction under the Trade Tax Act, interference is justified only where a question of law arises or the findings are shown to be illegal or perverse.

Conclusion: No question of law arose and the concurrent factual findings did not justify interference.

Final Conclusion: The revision was not entertained on merits and the order under challenge was left undisturbed, resulting in dismissal of the proceeding.

Ratio Decidendi: Revisional interference is not warranted against concurrent findings of fact in an assessment matter unless a substantial question of law, illegality, or perversity is shown; factual appreciation of account books and turnover estimation lies primarily with the fact-finding authorities.

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