Estimated addition for brick manufacture and stock upheld where sales disclosure and related filings supported factual finding of business activity.

Assessee's disclosure of brick sales, along with the application for compounding and late fee, supported the finding that brick manufacture and sale activity had occurred. The addition was made on estimation and was treated as a question of fact. The Tribunal, as the final fact-finding authority, upheld the assessment on the evidence available, and no legal infirmity was shown in that conclusion. Revision was therefore not warranted on the stated grounds.

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Issues: Whether the Tribunal was justified in sustaining the estimated addition made towards brick manufacture and stock, and whether any question of law arose warranting interference in revision.

Analysis: The assessee's own disclosure of brick sales during the assessment year, together with the application for compounding and late fee, supported the finding that there had been manufacturing and sale activity. The addition was made on estimation, which was treated as a question of fact. The Tribunal, being the final fact-finding authority, had upheld the assessment on the evidence available, and no legal infirmity was shown in that conclusion.

Conclusion: The estimated addition was upheld and the revision was not liable to interference.

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