Input tax credit cannot be denied when purchases preceded seller registration cancellation and the factual finding is not perverse.

Input tax credit could not be denied where the Tribunal found, as a matter of fact, that the assessee's purchases from the sellers were made before cancellation of their registrations. That factual finding was not shown to be perverse, and therefore could not be interfered with in revisional jurisdiction. On that basis, the grant of input tax credit was sustained in favour of the assessee, and the revision failed because no question of law arose from the Tribunal's order.

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Issues: Whether input tax credit could be denied on purchases made from sellers whose registrations had been cancelled, where the purchases were found to have been made before cancellation.

Analysis: The Tribunal recorded a factual finding that the respondent-assessee's purchases from the concerned sellers preceded the cancellation of their registrations. That finding was not shown to be perverse. In revisional jurisdiction, such a finding of fact was not open to interference.

Conclusion: The challenge to the grant of input tax credit failed, and the finding allowing the credit was sustained in favour of the assessee.

Final Conclusion: No question of law arose from the Tribunal's order, and the revision was dismissed.

Ratio Decidendi: A factual finding that purchases were made before cancellation of the seller's registration cannot be disturbed in revisional jurisdiction absent perversity, and input tax credit cannot be denied on that basis.

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