JUDGMENT PRAKASH KRISHNA, J. - These two revisions were heard together and are being disposed of by a common order. The disputes relate to the assessment years 1991-92 (Central) and 1992-93 (Central). The applicant, a public limited company, was granted eligibility certificate under section 4A of the U.P. Trade Tax Act, 1948 from July 4, 1985 for a period of six years. The goods manufactured by the dealer were exempt from payment of tax for the aforesaid period of six years both under the U.P. and Central Sales Tax Acts. After the expiry of the aforesaid period, it opened its own sales depot and branches at various places outside the State of U.P. The business premises of the applicant was surveyed on December 2, 1991. In the said survey some incriminating material was found. The assessing officer for these assessment years partly rejected the claim of the dealer with regard to the stock transfer. It has been treated as Central sales (Earlier there had been a remand order passed by the first appellate authority to the effect that the matter shall be examined afresh by the assessing authority). So far as assessment year 1991-92 (Central) is concerned, all the three authorities below have found on the basis of seized material that the applicant - dealer transferred vehicles outside the State of U.P. in pursuance of the purchase order given by its customers. The explanation furnished by the dealer has not been accepted. Shri Bharatji Agrawal, learned senior counsel for the applicant, submits that Faridabad depot was opened in July, 1991 after the expiry of the exemption period. Some old stationery was used by Faridabad depot with the result the presumption has been drawn that the applicant has made inter-State sales, wrongly. It is not the case of the applicant that the explanation furnished by it was not considered. If the authorities below have considered the explanations furnished by the applicant and have not found them sufficient, there appears to be no illegality. Acceptance or rejection of explanation is in the realm of the Tribunal which is the last fact finding authority. Non-acceptance of explanation by the Tribunal on sufficient grounds is no ground for interference by High Court in its revisional jurisdiction. So far as the assessment year 1991-92 is concerned, the findings recorded by the three authorities below are essentially finding of fact. Non-acceptance of explanation by the Tribunal on sufficient grounds is no ground for interference by High Court in its revisional jurisdiction. So far as the assessment year 1991-92 is concerned, the findings recorded by the three authorities below are essentially finding of fact. No illegality, or perversity therein could be pointed out by the learned senior counsel. No question of law is involved in the revision. The revision is concluded by finding of fact. It is therefore, dismissed. So far as the assessment year 1992-93 is concerned, the learned senior counsel strenuously submits that the Tribunal has dismissed the appeal filed by the dealer - applicant without recording finding its own on the issue whether the 16 vehicles which were allegedly sold to different Government Departments were transferred from the State of U.P. to outside the State of U.P. in pursuance of some prior contract. The learned standing counsel on the other hand submits that the relevant facts with regard to the assessment year 1992-93 have been considered by the Tribunal along with the facts relevant to the assessment year 1991-92. He invited the attention of the court towards the fact that in the earlier part of the order the Tribunal has recorded a relevant finding relevant to both the assessment years. The learned standing counsel also invited the attention of the court towards the finding recorded by the first appellate authority wherein it has been found by him that the 16 vehicles were transferred in the course of inter-State sale by the dealer. I have given careful consideration to the respective submissions of the counsel for the parties. A bare perusal of the order of the Tribunal, relating to the assessment year 1992-93 would show that the Tribunal has expressed its general agreement without recording any specific finding with the order of the first appellate authority. The Tribunal, being the last fact finding authority, should have considered the submissions of the applicant as to whether the transaction in question is stock transfer or inter-State sale by giving its own reasoning, may be in brief. The explanation furnished by the dealer - applicant in respect of 16 vehicles is that these vehicles were already lying in the depot and were sold to the party concerned from the depot. There was no prior contract of sale or purchase of these vehicles. The explanation furnished by the dealer - applicant in respect of 16 vehicles is that these vehicles were already lying in the depot and were sold to the party concerned from the depot. There was no prior contract of sale or purchase of these vehicles. Since the Tribunal has not examined this aspect of the case, it is desirable that the matter may be restored back to the Tribunal for fresh consideration. In the result, the order of the Tribunal so far it relates to the assessment year 1992-93 is concerned is hereby set aside. The matter is remanded back to the Tribunal to re-hear and re-decide the Appeal No. 1550 of 1999 relating to the assessment year 1992-93 (Central). In the result, the Trade Tax Revision No. 1111 of 2000 is dismissed while Trade Tax Revision No. 1460 of 2000 is allowed in part as indicated above. No order as to costs.