JUDGMENT : ( 1. ) AN ex parte order of assessment for the period between 1st April, 1973 and 31st March, 1978 under the M. P. General Sales Tax Act, 1958 (hereinafter referred to as "the Act") was passed by the Assistant Sales Tax Officer, Satna, on 16th October, 1978, on the ground that the petitioner was carrying on business of kifana and foodgrains. A revision was preferred by the petitioner against that order before the Deputy Commissioner of Sales Tax, Satna, and it was asserted by him that he was not doing any kirana or foodgrain business and that the said business was indeed being carried on by his father. This plea however, did not find favour with the Deputy Commissioner of Sales Tax who upheld the finding of the Assistant Sales Tax Officer on this point. He, however, remanded the matter back to the Assistant Sales Tax Officer for determination of the amount of tax and penalty afresh. ( 2. ) IN pursuance of the order of remand, the Assistant Sales Tax Officer, after hearing the petitioner, passed a fresh order of assessment for the aforesaid period on 16th November, 1981. No appeal or revision was filed by the petitioner against this order. The Assistant Sales Tax Officer passed another-order of assessment on 28th February, 1981 for the period from 1st April, 1978 to 31st March, 1979. A revision was filed by the petitioner against this order before the Deputy Commissioner of Sales Tax, which was dismissed by order dated 30th July, 1981. It is these orders which are sought to be quashed in the present writ petition. ( 3. ) IT has been urged by the learned counsel for the petitioner that it had been established by the petitioner that no kirana or grain business was carried on by him and the Assistant Sales Tax Officer as well as the Deputy Commissioner of Sales Tax have committed error in taking a contrary view. Suffice it to any, so far as this submission is concerned, that the question as to whether the petitioner was or was not carrying on kirana or grain business is essentially a question of fact. ( 4. ) FROM a perusal of the impugned order it appears that several opportunities were given to the petitioner to substantiate his claim but he failed to do so. ( 4. ) FROM a perusal of the impugned order it appears that several opportunities were given to the petitioner to substantiate his claim but he failed to do so. The finding recorded in the impugned orders being essentially a finding of fact, cannot be interfered with under Article 226 of the Constitution. On the facts of the instant case, it cannot be said that the said finding is perverse in the sense that it is based on no evidence. Material on which reliance has been placed for recording the aforesaid finding has been mentioned in the impugned orders. ( 5. ) IN regard to the order dated 16th November, 1981 which was passed by the Assistant Sales Tax Officer for the period from 1st April, 1973 to 31st March, 1978 consequent upon the order of remand passed by the Deputy Commissioner of Sales Tax it may further be pointed out that the petitioner failed to challenge the said order either by filing an appeal or a revision which was provided for in the Act. The present writ petition does not deserve to be entertained as against that order on this ground also. ( 6. ) THE learned counsel for the petitioner wanted to place reliance on some additional material in support of his submission that the petitioner was not carrying on kirana and grain business. Since a writ of certiorari goes against the record, reliance on any material, which was not placed before the authorities below, cannot be permitted to be placed for the first time in a writ of certiorari. ( 7. ) EVEN on merits, we are of the opinion that the impugned orders do not deserve- to be quashed on the basis of the additional material. One such additional material constitutes an order passed by the Assistant Sales Tax Officer on 30th October, 1983 in regard to the period from 1st April, 1979 to 31st March, 1980, which is a period subsequent to the period for which the impugned orders of assessment had been passed. Perusal of this order indicates that reliance was placed on a report of the Inspector. The other material which is sought to be relied on, is a copy of an order of the Deputy Commissioner of Sales Tax dated 27th April, 1983 whereby the matter was remanded in regard to the subsequent period between 1st April, 1979 to 31st March, 1980. The other material which is sought to be relied on, is a copy of an order of the Deputy Commissioner of Sales Tax dated 27th April, 1983 whereby the matter was remanded in regard to the subsequent period between 1st April, 1979 to 31st March, 1980. These orders, in our opinion, can hardly be said to have any bearing on the question as to whether the petitioner was carrying on kirana and grain business during the period in respect of which the impugned orders of assessment were passed. ( 8. ) IN the result, we find no merit in this writ petition. It is accordingly, dismissed. There shall be no order as to costs. The outstanding security amount may be refunded to the petitioner.