Quotations cannot be treated as sales without supporting material; turnover addition and consequential tax were upheld as deleted.

Quotations recovered during inspection could not, by themselves, be treated as sales where no sale bills were issued and no material showed actual transactions with buyers or contractors. The Tribunal held that the assessing authority had merely treated the quotation book as a sale bill without independent verification, and it deleted the estimated turnover and consequential tax addition. The HC found no error or illegality in that approach and held that no substantial question of law arose. The revision was therefore dismissed in favour of the assessee.

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Issues: Whether the Tribunal was right in deleting the estimated turnover and consequential tax addition made on the basis of quotations treated as sales, and whether the burden under section 10 of the Tamil Nadu General Sales Tax Act, 1959 lay on the assessee to prove that the quotations were not acted upon.

Analysis: The disputed addition was based on quotations recovered during inspection, but no sale bills had been issued against those quotations. The Tribunal found no material to show that the assessee had actually sold goods to any individual or contractor in respect of the items covered by the quotations. It also recorded that the assessing authority proceeded merely by treating the quotation book as a sale bill, without further probing or independent material to sustain the estimate. On that basis, the Tribunal deleted the turnover additions and the consequential tax. The revisional court found no error or illegality in that approach and held that no substantial question of law arose.

Conclusion: The deletion of the turnover addition and consequential tax was upheld, and the revision was dismissed in favour of the assessee.

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