Account reconciliation and documentary discrepancy resolved in favour of assessee; Tribunal orders set aside.

The assessee substantially satisfied the Revenue by reconciling the accounts and explaining the documentary discrepancy, with the remaining shortfall confined to a small amount and treated as attributable to the age of the matter. On that basis, the SC held the Revenue's concern had been adequately met and the appeals were allowed, setting aside the Tribunal's orders.

---

---

Issues: Whether the assessee had substantially satisfied the Revenue by reconciling the accounts and explaining the documentary discrepancy, so as to warrant setting aside the Tribunal's orders.

Analysis: The accounts were reconciled in the course of compliance proceedings, leaving only a small difference of Rs. 65,800/- and a documentary shortfall confined to that amount. The remaining discrepancy was treated as attributable to the age of the matter, and the assessee was found to have substantially met the Revenue's concern.

Conclusion: The issue was answered in favour of the assessee. The appeals were allowed and the Tribunal's orders were set aside.

---