Assessment findings upheld where bill-book records were considered, sales entries were undisputed, and no hearing prejudice was shown.

Assessment findings based on bill-book material were upheld because the authority had examined the copies produced, the revisionist did not effectively deny the absence of the original bill, and the disputed sales were reflected in the sales list before the assessing authority. The challenge to the factual findings also failed because no contradiction or perversity was shown. The plea of denial of hearing was rejected since notice had been issued, appellate opportunities were available, and no procedural prejudice was established before the final fact-finding authority. No ground for interference was therefore made out, and the revisions were not entertained.

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Issues: (i) whether the assessment authority failed to consider the bill book copies relied upon by the revisionist; (ii) whether the finding regarding sale entries in the bill book and sales list suffered from error; (iii) whether the assessment and appellate proceedings were vitiated for want of opportunity of hearing.

Issue (i): whether the assessment authority failed to consider the bill book copies relied upon by the revisionist

Analysis: The assessment order showed that the authority had examined the bill book produced by the revisionist and found that the original bill was not contained in it. The challenge was further weakened because this factual aspect was not effectively denied in the later appellate stages.

Conclusion: The issue was decided against the revisionist.

Issue (ii): whether the finding regarding sale entries in the bill book and sales list suffered from error

Analysis: The revisionist did not dispute the finding that the disputed sales had been reflected in the list of sales placed before the assessing authority. In the absence of any denial or material contradiction, no infirmity was found in the factual conclusion recorded below.

Conclusion: The issue was decided against the revisionist.

Issue (iii): whether the assessment and appellate proceedings were vitiated for want of opportunity of hearing

Analysis: Notice had been issued before assessment, and the revisionist had opportunities in appeal to contest the adverse findings. The Tribunal, being the final fact-finding authority, did not commit any perversity or illegality warranting interference, and no procedural prejudice was established.

Conclusion: The issue was decided against the revisionist.

Final Conclusion: No ground for interference was made out, and the revisions did not warrant admission or relief.

Ratio Decidendi: A revision will not be interfered with at the admission stage where the assessment authority has considered the material, the factual findings are not shown to be perverse, and no denial of hearing causing prejudice is established before the final fact-finding authority.

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