Loose survey papers used for bank financing cannot prove actual sales when factual findings reject real turnover.

Loose papers found during survey were accepted as projected figures prepared to obtain higher bank cash credit facilities, not as evidence of actual sales. The first appellate authority and the Tribunal treated the explanation as credible and held that the figures did not represent real turnover. That finding was treated as one of fact, so revisional interference was not justified absent perversity or lack of basis. The statutory provision on reliance upon documents did not override the factual conclusion that the papers did not reflect actual sales. The disputed documents therefore could not support reopening or reassessment on the footing of undisclosed turnover.

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Issues: Whether the loose documents found during survey, stated to have been prepared for obtaining higher cash credit facilities from a bank, could be treated as evidence of actual sales so as to justify reopening and reassessment under the Trade Tax law.

Analysis: The material on record showed that the assessee's explanation for the seized papers was accepted by the first appellate authority and the Tribunal. The Tribunal found no error in that view and held that the figures in the loose papers did not represent actual turnover but were projected figures used for banking purposes. Such a conclusion was treated as a finding of fact. In revision, interference was unwarranted unless the finding was shown to be perverse or without basis, which was not established. The cited statutory provision regarding reliance on documents did not displace the factual finding that the papers did not reflect real sales.

Conclusion: The disputed papers could not be treated as proof of actual turnover, and the Tribunal's factual finding did not call for interference.

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