Perversity standard in gold purchase reassessment upheld where evidence supported inflated purchases and alleged stock suppression.

The HC upheld the addition for alleged inflated gold purchases and the related finding of suppression of 25 kilograms of gold, holding that the reassessment was supported by audited accounts, purchase particulars, stock records and brand markings. The assessee's explanation about earlier receipt, later billing and replacement was found inconsistent with the record. The Court accepted that the Assessing Officer, CIT(A) and Tribunal had adopted a possible view on the evidence, and the factual findings were not shown to be perverse. The challenge to the addition therefore failed.

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Issues: (i) Whether the addition of Rs. 1,51,09,660 on account of alleged inflated purchase and the consequential finding of suppression of sale of 25 kilograms of gold were perverse or unsupported by the record.

Analysis: The reassessment was founded on the audited accounts and the purchase details, which showed a mismatch between the total purchase figure and the partywise and quantity-wise particulars. The assessee's explanation regarding gold received earlier, later billed, and allegedly replaced was found inconsistent with the stock records, the brand markings, and the disclosed figures. The authorities below treated the excess debit and the assessee's shifting stand as establishing either an inflated purchase entry or, on the assessee's later version, a corresponding unaccounted closing stock which was absent. The findings of the Assessing Officer, the Commissioner (Appeals), and the Tribunal were held to be possible views on the evidence, not perverse.

Conclusion: The challenge to the addition failed and the finding against the assessee was upheld.

Final Conclusion: The appeal was dismissed because the assessee failed to dislodge the revenue's case on the disputed gold purchase entries and the factual findings were not shown to be perverse.

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