Concurrent factual findings on missing transport documents upheld; delayed production did not rebut inference of tax evasion.

Concurrent findings that goods were transported without supporting documents, later produced only after about 15 days, were upheld as sufficient to support an adverse inference of tax evasion and justify seizure under Section 48(7) of the Uttar Pradesh Value Added Tax Act, 2008. The Court found no plausible explanation for the delayed production of documents and no perversity in the authorities' conclusion. Subsequent filing of papers did not displace the factual inference drawn from the circumstances, so revision did not warrant interference and no question of law arose.

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Issues: Whether the concurrent findings recorded by the tax authorities and the Tribunal, that the assessee intended to evade tax and that seizure of goods was justified under Section 48(7) of the Uttar Pradesh Value Added Tax Act, 2008, called for interference in revision or gave rise to any question of law.

Analysis: The goods were found loaded on the transport vehicle without the relevant documents at the time of survey. The assessee produced the documents only after about 15 days, and no plausible explanation was offered for the failure to present them promptly before the authorities. On these facts, the authorities drew an adverse inference that the documents were procured later and that there was an intention to evade tax. The findings were concurrent findings of fact, and nothing on record showed perversity in those findings. Mere subsequent production of documents was not enough to displace the inference drawn from the circumstances.

Conclusion: No interference was warranted with the concurrent factual findings, and no question of law arose for adjudication.

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