Input tax credit on verified purchases from registered dealers with bank payments resisted revisional interference

Input tax credit on purchase transactions was upheld where the Tribunal, as the final fact-finding authority, verified that the selling dealers were registered during the relevant period and that payment was made through banking channels. The Assessing Authority's denial, based on third-party information treating the sellers as unregistered, was not sustained because the Tribunal's factual findings were supported by the record and were not shown to be materially disputed. In such circumstances, no question of law arose for revisional interference, and the dealer's claim remained allowed.

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Issues: Whether the Tribunal was justified in allowing input tax credit on purchases after verifying that the selling dealers were registered and the transactions were supported by banking records.

Analysis: The Assessing Authority had denied input tax credit on the basis of information received from the Special Investigation Officer and treated the purchases as having been made from unregistered dealers. The Tribunal, acting as the final court of fact, reappreciated the material, verified the dealers on the official departmental website, and recorded a factual finding that the sellers were duly registered during the relevant period and that payments were made through bank. The record and the finding of the Tribunal were not shown to be disputed on material particulars, and no question of law arose from the factual determination.

Conclusion: The Tribunal was justified in granting input tax credit, and the revisions failed.

Final Conclusion: The common revisional challenge to the Tribunal's factual finding was rejected, and the orders allowing the dealer's claim were left undisturbed.

Ratio Decidendi: Where the final fact-finding authority records a verified factual finding that purchases were from registered dealers and payments were made through bank, no question of law arises for interference in revision on the denial of input tax credit.

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