JUDGMENT OM PRAKASH, C.J. – Heard counsel for the parties. 2. The short question for consideration in these revision petitions is whether the Sales Tax Appellate Tribunal was right in upholding the additions made by the assessing officer on account of purported unaccounted purchases of arrack by the revision-petitioner. 3. The revision-petitioner is an abkari contractor. She made purchases of arrack from the distilleries, owned and controlled by the Government of Kerala during the year 1986-87 and had paid tax on such purchases at the point of purchase. It is not disputed that sales of arrack are taxable only at the point of first sale within the State. 4. The assessing officer found some discrepancies in the books of accounts of the revision-petitioner and drew an inference therefrom that the revision-petitioner had made unaccounted purchases of arrack. He therefore, made a best judgment assessment and made the addition of the amount of Rs. 4,03,000. On appeal, the first appellate authority reduced the addition to Rs. 2,01,500. 5. Aggrieved, the Sales Tax Department carried the dispute further in appeal before the Sales Tax Appellate Tribunal, which set aside the order of the first appellate authority and restored the addition made by the assessing officer. 6. The submission of learned counsel for the revision-petitioner before us is that whatever discrepancies in the books of accounts, were there, they related only to the transactions made in regard to the purchases from the Government distillery on which tax was already paid and that there is nothing on record to indicate that the revision-petitioner made unaccounted purchases liable to be taxed. It is submitted before us that arrack is not a salable commodity in the open market and that it could be purchased only from the Government distilleries. It is submitted that simply because the books of accounts are not completely posted on the date of inspection, no inference could be drawn that the revision-petitioner had made unaccounted purchases. On inspection, certain shortage was noticed. The learned Standing Counsel himself submits that no addition could be made only on account of shortages. The addition is based on the ground of unaccounted purchase of arrack. The learned Government Pleader simply argues that since the books of accounts are not regularly posted by the revision petitioner, an inference could be drawn that the revision petitioner had made unaccounted purchases. The addition is based on the ground of unaccounted purchase of arrack. The learned Government Pleader simply argues that since the books of accounts are not regularly posted by the revision petitioner, an inference could be drawn that the revision petitioner had made unaccounted purchases. As already pointed out, since arrack could be purchased only from the Government distilleries, it is for the respondents to explain as to wherefrom the unaccounted purchases were made by the revision petitioner. No cogent explanation whatsoever has been given by the respondents. 7. Simply because the books of accounts were not found to be fully posted at the time of the inspection, we are of the view that no addition could be made only for that reason drawing the inference that the books of accounts were not fully and regularly posted because the revision-petitioner involved herself in unaccounted purchases. The respondents should have adduced some evidence to establish that unaccounted purchases had been made by the revision petitioner to justify the addition made on that account. There is no cogent material on the record to support this averment. For these reasons, both the revisions succeed and are allowed and the impugned addition of Rs. 4,03,000 is deleted. Petitions allowed.