Input tax credit reversal on scrap sales failed where suppression and stock discrepancy were not proved, leaving no substantial question of law.

Concurrent findings that the audit did not establish purchase suppression or sales suppression, and that the stock discrepancy was negligible, justified deletion of the proposed input tax credit reversal on scrap sales. The HC held that the dealer's sale of finished goods and scrap on first sale, with tax paid after adjusting input tax credit, did not raise any substantial question of law for interference in tax revision. On that basis, the challenge to reopening the assessment failed and the revisions were dismissed.

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Issues: Whether reversal of input tax credit on the sale of scrap was justified and whether any substantial question of law arose from the findings on suppression and stock discrepancy.

Analysis: The dealer manufactured stainless steel utensils, sold finished goods and scrap on first sale, and paid tax after adjusting input tax credit. The appellate authority and the Tribunal found that the audit did not establish purchase suppression or sales suppression, the stock discrepancy was negligible, and there was no admission supporting the reversal proposal. The High Court accepted these concurrent factual findings and held that the assessment revision based on the sale of scrap did not disclose any substantial question of law.

Conclusion: The challenge to the deletion of the input tax credit reversal failed, and the revisions were dismissed.

Final Conclusion: The concurrent findings in favour of the dealer were upheld, and the assessments were not reopened on the alleged scrap-sale discrepancy.

Ratio Decidendi: Concurrent findings of fact, unsupported by evidence of suppression or a real stock discrepancy, do not give rise to a substantial question of law for interference in tax revision.

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