Turnover enhancement for crossing a tax threshold is unjustified when actual stock variation has already been accounted for.

Where stock variation found on inspection was later brought into the accounts, an equal addition to turnover was unwarranted. The first appellate authority's view that the actual suppression alone sufficiently covered probable omission was held to be just and reasonable. The revisional authority could not enhance the turnover artificially merely to push it above the threshold for additional sales tax, and the enhancement was not sustained. The assessee was entitled to relief from the revised assessment.

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Issues: Whether the revisional authority was justified in enhancing the turnover by making an equal addition and by refixing the turnover above the threshold, instead of accepting the first appellate authority's view that only the actual suppression should be added.

Analysis: The variation found during inspection had subsequently been brought into account by the assessee. In that situation, the addition of twice the actual variation was held to be unwarranted. The first appellate authority's approach of treating the actual suppression as sufficient towards probable omission was found to be just and reasonable. The revisional authority's enhancement was made only to raise the taxable turnover above the threshold for attracting additional sales tax, which was not supported on the facts.

Conclusion: The revision was unjustified and the assessee was entitled to relief; the turnover enhancement made by the revisional authority could not be sustained.

Ratio Decidendi: Where stock variation found on inspection is subsequently accounted for and the addition of actual suppression is adequate, a revisional authority cannot enhance turnover by making an artificial equal addition merely to cross a tax threshold.

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