Stock variation and unexplained survey material justified rejection of books and best judgment assessment in revision.

Stock variation and unexplained material found during survey supported rejection of the books of account and a best judgment assessment. The appellate authority had already granted partial relief after examining the evidence, and the remaining adverse inference on disputed papers and stock discrepancy was not satisfactorily explained. As the revision did not successfully challenge the factual findings forming the basis of the assessment, the High Court found no legal infirmity warranting interference. The revision was dismissed and the assessment-based position was upheld.

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Issues: Whether the Tribunal's order upholding rejection of books of account and best judgment assessment on the basis of stock variation and material found in survey called for interference in revision.

Analysis: The assessment was based on survey findings, including loose papers and variation in stock, and the appellate authority had already granted partial relief after examining the material. The remaining adverse inference regarding the disputed papers and stock discrepancy was not satisfactorily explained. The revision did not assail the factual findings on stock variation, which formed the foundation for rejecting the books of account and making the best judgment assessment.

Conclusion: The impugned order suffered from no legal infirmity warranting interference. The issue is answered against the revisionist.

Final Conclusion: The revision was dismissed and the Revenue's assessment-based position was upheld.

Ratio Decidendi: Where findings of stock variation and unexplained material from survey remain unchallenged, rejection of books of account and best judgment assessment will not be interfered with in revision.

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