Concurrent findings and bogus consignments upheld where evidence failed to show genuine trade or crossing of goods frontier.

Concurrent factual findings that the purchaser was not a genuine dealer and that the consignments were bogus were left undisturbed, because the revision court found no material basis to overturn the sales tax penalty. The authorities relied on the check-post endorsement, intelligence report, absence of proof of business at the declared address, failure to show that goods crossed the State frontier, and the doubtful nature of the C forms and related documents. A registration certificate alone was held insufficient to displace these findings, and the consistency of three fact-finding authorities meant revisional interference was unwarranted.

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Issues: Whether interference was warranted with the concurrent finding that the purchaser was not a genuine dealer and that the consignments were bogus, so as to upset the penalty imposed under the sales tax law.

Analysis: The revision court examined the materials relied upon by the authorities, including the check-post endorsement, the intelligence report, the absence of proof that the purchaser was functioning at the declared address, the lack of evidence that the goods actually crossed the State frontier, and the doubtful nature of the C forms and related documents. The registration certificate by itself was held insufficient to dislodge the factual conclusion that the purchaser was not carrying on business and that the documents produced did not inspire confidence. Since three fact-finding authorities had reached the same conclusion on appreciation of evidence, and the material did not justify a contrary inference, no ground for revisional interference was made out.

Conclusion: The concurrent finding that the transaction was not genuine and that penalty was validly levied was upheld, and interference was declined.

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