Concurrent factual findings and bogus Form-F declarations barred revisional interference with reassessment and exemption denial.

Revisional interference with reassessment was refused because the authorities below had recorded concurrent findings that the assessee's Form-F declarations were bogus and that the claimed consignment or inter-State sales were not proved. The High Court noted that service of notice, the validity of the reassessment proceedings, and the genuineness of the supporting declarations were all decided on the material on record, and no perversity, illegality, or contradiction with the record was shown. In the absence of any such defect, no substantial question of law survived, so the reassessment and denial of exemption were maintained.

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Issues: Whether the reassessment and denial of exemption on alleged consignment sales, based on the finding that the Form-F declarations were bogus, could be interfered with in revision in the absence of perversity in the factual findings.

Analysis: The revision challenged the reassessment order and the concurrent findings of the appellate authorities and the Tribunal on service of notice, the validity of the reassessment proceedings, and the genuineness of the Form-F declarations supporting the claimed inter-State/consignment sales. The Court found that the authorities below had recorded concurrent findings of fact against the assessee on the basis of the material on record, and nothing was shown to establish that those findings were perverse, contrary to the record, or otherwise illegal. In such circumstances, no substantial question of law survived for interference in revision.

Conclusion: The findings sustaining the reassessment and rejecting the claim for exemption were upheld, and the revision was decided against the assessee.

Final Conclusion: Concurrent factual findings refusing relief under Section 6-A were not disturbed in revisional jurisdiction, resulting in dismissal of the revision.

Ratio Decidendi: Concurrent findings of fact can be interfered with in revision only if they are shown to be perverse, contrary to record, or legally unsustainable.

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