Revisional interference limited to perversity, with Tribunal's factual finding on single diversification upheld for exemption claim.

Revisional interference was refused because the Tribunal's view that the assessee's shift into refrigerators and PC monitors was one composite diversification exercise rested on evidence and not on perversity, absence of evidence, or disregard of relevant material. The Court reiterated that revisional jurisdiction is narrow and cannot disturb concurrent factual findings merely because another view is possible. Although the assessee bore the burden to prove single diversification for exemption, the Tribunal's appreciation of approval letters, disclosures, invoices, plant and machinery details, and production dates was upheld. The claim for exemption therefore remained undisturbed, and the revision failed on facts disguised as a question of law.

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Issues: Whether the Tribunal's finding that the assessee's diversification into refrigerators and PC monitors was a single diversification exercise, warranting exemption, suffered from any legal infirmity, perversity, or warranting interference in revisional jurisdiction.

Analysis: The dispute turned on appreciation of evidence and the scope of revisional interference. The Court held that the Tribunal had examined the materials placed by both sides, including approval letters, annual report disclosures, invoices, plant and machinery details, and production-related dates, and had recorded a factual conclusion that the diversification was undertaken as one composite exercise. The Court reiterated that revisional jurisdiction is limited and that concurrent factual findings can be interfered with only if they are perverse, based on no evidence, or ignore relevant material. It found that the revenue had not shown any such perversity or illegality. The Court also accepted that the burden to establish single diversification lay on the assessee, but held that the Tribunal's factual appreciation on that burden could not be disturbed in revision.

Conclusion: The Tribunal's finding of single diversification was upheld and no revisional interference was warranted.

Final Conclusion: The revision was not maintainable on facts in the guise of a question of law, and the Tribunal's allowance of the assessee's claim remained undisturbed.

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