JUDGMENT The judgment of the Court was delivered by P. SHANMUGAM, J. - The petitioner is a registered dealer under the Kerala General Sales Tax Act, 1963. The petitioner is carrying on business in Indian-made foreign liquor. During the assessment year 1981-82 the petitioner had purchased Indian-made foreign liquor from local dealers as well as from outside the State. According to the petitioner, he is not liable to pay sales tax in respect of purchases made from local dealers since Indian-made foreign liquor is taxable at single point, at the point of first sale in the State of Kerala. His liability is confined to the sales turnover relating to the goods purchased from outside the State. 2. For the assessment year 1981-82 the petitioner submitted an annual return showing the total and taxable turnover as Rs. 23,01,420 and Rs. 86,000, respectively. The Sales Tax Officer by order dated February 22, 1984 fixed the total and taxable turnover at Rs. 23,66,043.70 and Rs. 1,50,620 respectively. The taxable turnover was estimated at Rs. 1,50,620 as against Rs. 86,000 submitted by the petitioner, by rejecting the accounts and making an estimated addition of 10 per cent for probable omission and also by estimating a gross profit of 40 per cent on the value of goods sold. On appeal the Appellate Assistant Commissioner by order dated February 12, 1985 om S.T.A. No. 707 of 1984 deleted the addition of 10 per cent for probable omission as well as the estimate of 40 per cent gross profit. The order confined the addition to 10 per cent of the taxable turnover declared by the petitioner, viz., Rs. 86,000 and consequently the taxable turnover was reduced to Rs. 94,600 from Rs. 1,50,620. On appeal by the Revenue before the Appellate Tribunal, the Tribunal allowed the appeal and set aside the order of the Appellate Assistant Commissioner and restored the assessment order of the Sales Tax Officer. The tax revision case has raised, inter alia, the question whether the Appellate Tribunal was justified in reversing the findings of the Appellate Assistant Commissioner on the facts of the case. 3. The tax revision case has raised, inter alia, the question whether the Appellate Tribunal was justified in reversing the findings of the Appellate Assistant Commissioner on the facts of the case. 3. Learned counsel appearing on behalf of the petitioner referred to a decision in P. P. Raju v. State of Kerala (1993) KLJ (TC) 371, wherein it was held that where the first appellate authority has, for reasons of its own, set aside the quantum of estimate made by the assessing authority, a duty is cast on the Appellate Tribunal to demonstrate as to how or in what manner the first appellate authority erred in interfering with the estimate made by the assessing authority before substituting its own figure of estimate or restoring the estimate made by the assessing authority. The Division Bench set aside the order of the Tribunal on the ground that no reasons were given by the Tribunal before entering into the findings. The fact on hand would not in any way attract the ratio laid down by the said decision. It is only in cases where that Tribunal without giving reasons interferes with the order of the first appellate authority, there is scope for invoking the said principle. In the case on hand the Tribunal has given cogent and valid reasons for restoring the order of the assessing authority. The assessing officer has found that the purchase value of goods from outside the State, viz., Rs. 99,724.50 is excluding the excise duty paid, viz., Rs. 94,500. The closing stock as per account was Rs. 96,417. This value of closing stock is inclusive of excise duty paid. Therefore, the assessing authority came to the conclusion that the sale turnover of taxable items reported was not correct. Accordingly by adding 40 per cent gross profit as per accounts arrived at, the assessing authority fixed the sale value at Rs. 1,36,930.50. After inspection by the Intelligence Officer and on further verification certain irregularities have been noted and therefore, the Sales Tax Officer rejected the accounts submitted by the assessee as incorrect and estimated the total and taxable turnover as Rs. 23,66,043.70 and Rs. 1,50,620 respectively. The Tribunal found that if the basis adopted by the Appellate Assistant Commissioner is adopted, the taxable turnover will be below the purchase value of goods sold, viz., Rs. 94,000 against the purchase value of goods sold, viz., Rs. 97,807.50. 23,66,043.70 and Rs. 1,50,620 respectively. The Tribunal found that if the basis adopted by the Appellate Assistant Commissioner is adopted, the taxable turnover will be below the purchase value of goods sold, viz., Rs. 94,000 against the purchase value of goods sold, viz., Rs. 97,807.50. No reasons or circumstance acceptable were furnished by the assessee for the low sales turnover below the purchase value. The details of the stock in respect of the items were not made available before the assessing authority or before the Appellate Assistant Commissioner. Therefore, the assessing officer has rightly estimated the total and taxable turnover. The Tribunal has given a finding that the inspection conducted revealed an excess stock which also shows that there were unaccounted purchase and the resultant suppression in taxable sales. Considering all these facts and circumstances the Tribunal was justified in restoring the order of the assessing authority. 4. In view of these factual findings by the Tribunal we do not find any question of law that arises for consideration in this tax revision case. Accordingly we dismiss the tax revision case. Petition dismissed.