Collector's certificate accepted as bona fide public document, with appellate relief sustained against the Revenue challenge.

A Collector's certificate was accepted as valid where the Revenue failed to produce any material discrepancy to discredit it. The certificate, issued by a public servant, was treated as bona fide, in good faith, and in public interest. In the absence of contrary evidence, the Commissioner (Appeals)' appreciation of the certificate disclosed no legal infirmity, so the appellate benefit based on that certificate was sustained and the Revenue's challenge failed.

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Issues: Whether the Collector's certificate could be accepted as valid and sufficient, and whether the order of the Commissioner (Appeals) upholding the benefit based on that certificate called for interference in the Revenue's appeal.

Analysis: The Revenue failed to bring any material discrepancy to discredit the certificate issued by a public servant. A certificate issued by a Collector was treated as having been issued bona fide, in good faith, and in public interest. In the absence of contrary evidence, the lower appellate authority's appreciation of the certificate did not suffer from legal infirmity.

Conclusion: The certificate was accepted, and the order of the Commissioner (Appeals) was upheld against the Revenue.

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