Writ interference with factual findings is limited where interpolations in stock records are supported by material evidence.

Interpolations in the stock register and delivery challans were found on the basis of the stock book and connected records, and the dealer could not correlate stock movements with the inspection findings. The High Court held that these were supported factual findings and, in writ jurisdiction under Article 226, it would not reappreciate evidence or disturb the Tribunal's conclusions absent illegality or perversity. The challenge therefore failed, and the order restoring the assessment and setting aside the appellate order was upheld.

---

---

Issues: Whether the Tribunal's finding that the stock register and delivery challans contained interpolations and that the assessment deserved restoration could be interfered with in writ jurisdiction.

Analysis: The Tribunal recorded a specific factual finding, based on the stock book and connected records, that the entries had been interpolated and that the dealer was unable to correlate the stock movements with the inspection findings. The High Court held that such findings were supported by material evidence. In exercise of jurisdiction under Article 226 of the Constitution of India, the Court would not reappreciate evidence or interfere with factual conclusions unless illegality or perversity was shown. No such infirmity was made out.

Conclusion: The Tribunal's order restoring the assessment and setting aside the appellate order was upheld, and the challenge failed.

---