Branch import suppression must be supported by transfer and movement records; unsupported centralised handling cannot defeat the addition.

An import booked in a branch name must be reflected in that branch's accounts; a claim that the transaction was centrally handled and later moved to other branches requires supporting transfer and interstate movement records. In the absence of such documents, the assessee's explanation was not accepted and the suppression stood established on the surrounding facts and admission. The Tribunal's deletion of the addition was held perverse because it ignored the evidentiary deficiency, and the assessment was restored in respect of the suppressed import.

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Issues: Whether the Tribunal was justified in deleting the addition made on account of purchase suppression, and whether the assessee's explanation for not recording the import in the accounts could be accepted under the Kerala Value Added Tax Act, 2003.

Analysis: The import of gold was made in the name of the branch, but it was not reflected in the branch accounts. The explanation that the import was centrally controlled by the head office and later moved to other branches was not supported by documents showing branch transfer or interstate movement. In the absence of such supporting material, the suppression stood established on the assessee's own admission and surrounding facts, and the Tribunal ought not to have deleted the addition merely because the assessment order was brief.

Conclusion: The questions were answered against the assessee and in favour of the Revenue. The deletion of the addition by the Tribunal was held to be perverse, and the assessment was restored in respect of the suppression.

Final Conclusion: The revision was allowed, the Tribunal's order was set aside, and the assessment relating to the suppressed import was restored.

Ratio Decidendi: An import made in the branch name must be accounted in the branch books, and a claim of centralized handling or inter-branch movement must be supported by proper transfer and movement documents; otherwise, suppression is established and an appellate deletion of the addition is unsustainable.

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