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Issues: Whether the revisional order under Section 34 of the Tamil Nadu General Sales Tax Act, 1959, restoring the addition and penalty was sustainable when the disputed entries had already been accounted for in the regular books.
Analysis: The disputed transactions found in the note book and D7 records were found reflected in the day book and supported by purchase bills. The Court treated the suppression allegation as unproved because the entries had been brought into account before assessment, and therefore the transactions could not be characterised as unaccounted sales or purchases. In such circumstances, only a limited addition for defects in accounting, if any, could survive. The Court also followed the earlier binding view that revision is not warranted unless there is a patent error of law or perversity.
Conclusion: The revisional order was unsustainable and liable to be quashed.
Ratio Decidendi: Once disputed stock or transactions are shown to have been duly entered in the regular accounts before assessment, actual suppression is not established and revisional interference is not justified absent a patent error of law or perversity.