Revisional interference requires engagement with material evidence before disturbing deletion of turnover and penalty.

A revisional authority cannot overturn an appellate finding deleting disputed turnover and penalty without meeting the assessee's specific factual explanation and supporting records. Here, the assessee's explanation that the voucher entry was inadvertent, the goods had already been received and entered in the pass register, and there was no business of selling beedi leaves was accepted by the appellate authority, which treated the purchase as an intra-State purchase from a registered dealer and not taxable under Section 7A of the Tamil Nadu General Sales Tax Act, 1959. The revisional authority rejected that explanation without addressing the material evidence, so its interference was held unjustified and the appellate order was restored.

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Issues: Whether the revisional authority was justified in interfering with the appellate order deleting the disputed turnover and setting aside the penalty on the ground of alleged unaccounted stock and suppression.

Analysis: The assessee's explanation was that the voucher entry was inadvertent, the goods had been received earlier and were recorded in the pass register, and there was no business of selling beedi leaves. The appellate authority accepted the explanation on the basis of the records and held that the disputed purchase was an intra-State purchase from a registered dealer and could not be brought to tax under Section 7A of the Tamil Nadu General Sales Tax Act, 1959. The revisional authority, however, did not deal with the specific factual explanations or the supporting register entries and rejected the case as unbelievable without addressing the material evidence.

Conclusion: The revisional interference was unjustified. The order of the revisional authority was set aside, the appellate order was restored, and the deletion of the disputed turnover and the setting aside of penalty stood upheld in favour of the assessee.

Ratio Decidendi: A revisional authority must examine and meet the assessee's specific factual explanation and supporting records before upsetting an appellate finding deleting turnover and penalty; a conclusory rejection without dealing with the material evidence cannot stand.

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