Sales suppression not proved from inspection slips; reopening of the completed assessment was unjustified.

Slips recovered during inspection did not constitute reliable material to show sales suppression where the dealer had closed business before the relevant year, kept no regular books apart from the cash book, and the disputed slips were found to be estimate slips already accounted for by a sister concern. One slip contained only an inserted year, and another showed stock particulars without supporting sale details such as consignor, consignee, date, items sold, or mode of payment. As the additional documents did not displace the concurrent factual findings, reopening of the completed assessment under section 16(1) of the Tamil Nadu General Sales Tax Act, 1959 was not justified and the revision was rejected.

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Issues: Whether the slips recovered during inspection constituted material showing sales suppression so as to justify reopening of the completed assessment under section 16(1) of the Tamil Nadu General Sales Tax Act, 1959.

Analysis: The respondent had closed business before the relevant year and maintained no regular books except the cash book. The slips relied upon by the department were found by the appellate authority and the Tribunal to consist largely of estimate slips already accounted for by the sister concern, and did not show any independent unaccounted sale. Slip No. 10 contained an insertion of the year, while Slip No. 11 contained only stock particulars such as weight and value without supporting sale particulars like consignor, consignee, date of sale, items sold or mode of payment. The additional documents filed by the department did not displace these concurrent findings or establish any material to reopen the assessment.

Conclusion: The slips did not establish sales suppression, and initiation of proceedings under section 16(1) of the Tamil Nadu General Sales Tax Act, 1959 was not justified. The revision petition was therefore liable to be rejected.

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