Loose papers and survey records supported estimated tax liability, with no perversity or substantial question of law shown.

The Tribunal's estimate of tax liability was upheld because the survey material, including loose papers, matched purchase and sales details such as dates, vehicle numbers, quantity, value and names, while the books produced did not correspond to those records. The dealer had not produced the required books of account during survey, and the Tribunal had already substantially reduced the turnover while sustaining rejection of the books. A discrepancy in one loose paper was treated as a typographical error and did not undermine the findings. No perversity or substantial question of law was shown under the U.P. VAT Act, 2008, so the revisions failed.

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Issues: Whether the Tribunal's findings sustaining the estimated tax liability were perverse or based on misreading of the loose papers, and whether any substantial question of law arose under Section 58 of the U.P. VAT Act, 2008.

Analysis: The Court found that the survey material, including the loose parchas, tallied with purchase and sales details such as dates, vehicle numbers, quantity, value and names of persons. It also noted that the parchas did not mention invoice or book numbers and could not be matched with the books produced. The revisionist had not produced the required books of account during the survey, and the Tribunal had already substantially reduced the turnover while sustaining rejection of the books. The alleged discrepancy regarding the figure in loose parcha no. 5 was found to be only a typographical error and not a basis for interference.

Conclusion: The Tribunal's order was not perverse, no legal issue was shown to exist, and the revisions failed.

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