Unaccounted stock taxation displaces confiscation where assessment provisions apply, leaving no standalone basis to restore a fine.

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....Unaccounted bricks and coal found during survey are to be taxed by treating the goods as supplied and applying assessment provisions, rather than through confiscation proceedings and penalty for excess stock. Where the entire confiscation order, including penalty and fine in lieu of confiscation, has been quashed and that finding remains unchallenged, no separate basis survives to maintain or restore the fine. Revenue appeals limited to restoration of the fine were therefore dismissed.....