Unexplained purchases in sugar trading not established where books, bills, VAT records and confirmations supported accounted transactions.

The Tribunal's deletion of the addition for alleged unexplained purchases and investment in sugar was sustained because the purchases were supported by regular books, audited accounts, bills, confirmations, VAT records, and identified registered traders' statements. Revenue material from raid proceedings and statements before the Food & Civil Supplies Department did not displace the documentary record showing accounted transactions. As the dispute depended on appreciation of facts and the Tribunal's view was not shown to be perverse, no substantial question of law arose.

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Issues: Whether the Tribunal was justified in deleting the addition made on account of alleged unexplained purchases and investment in sugar and whether any substantial question of law arose from the factual findings.

Analysis: The sugar purchases were supported by regular books of account, audited accounts, bills, confirmations from the parties, and VAT records. The parties were identified traders with tax registration numbers, and their statements were recorded. The material relied upon by the revenue from the raid proceedings and the assessee's statements before the Food & Civil Supplies Department did not displace the documentary evidence showing accounted transactions. The dispute turned on appreciation of facts, and the Tribunal's view that there was no material to treat the transactions as outside the books was not shown to be perverse.

Conclusion: The deletion of the addition was upheld and no substantial question of law was found to arise.

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