Proved purchase suppression sustains equal addition and reduced penalty, with no revisional interference on factual findings.

Inspection materials showed that the assessee had failed to account for goods received from its branch office and had not maintained accounts in the ordinary course of business. That factual suppression was treated as proved, and the equal addition for probable omission was sustained because the unaccounted receipt supported the inference of suppressed turnover. The penalty was also upheld, though reduced from 150 per cent to 50 per cent, in view of the established suppression and the likelihood of tax evasion. Revisional interference was therefore found unwarranted, and the Tribunal's reliefs and modifications remained undisturbed.

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Issues: Whether the findings of purchase suppression and the consequential equal addition and reduced penalty were liable to be interfered with in revision.

Analysis: The inspection materials showed that the assessee had not accounted for the receipt of goods from its branch office and that the accounts were not maintained in the ordinary course of business. The suppression was treated as factual and proved, and the Tribunal found that the unaccounted receipt of goods justified the equal addition for probable omission. The Tribunal also sustained the levy of penalty, but reduced it from 150 per cent to 50 per cent, taking note of the established suppression and the likelihood of tax evasion.

Conclusion: The findings on suppression, equal addition and penalty were upheld and no interference was warranted in revision.

Final Conclusion: The revision failed and the Tribunal's reliefs and modifications remained undisturbed.

Ratio Decidendi: Where suppression of receipts is proved on inspection and the factual findings are not perverse, revisional interference with consequential addition and penalty is unwarranted.

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