JUDGMENT Akil Kureshi, J. - The assessee is in the appeal against the judgment of the Income Tax Appellate Tribunal raising following questions for our consideration:- "(i) Whether on the facts and in the circumstances of the case and in law, the findings of the Tribunal that the books of accounts of the appellant are unreliable and the finding that appellant has claimed a higher processing loss, is perverse being arrived at without considering the relevant evidence / material and documents furnished and submissions made by the appellant? (ii) Whether on the facts and in the circumstances of the case and in law, the Tribunal was justified in upholding the rejection of books of accounts of the appellant and the adhoc addition made by the respondent of 4.3% in the gross profits, amounting to Rs. 96,98,214/- as suppressed sale, without considering the relevant evidence / material / documents furnished and submissions made, by the appellant? 2. Appellant assessee is engaged in manufacturing of bulk drugs. The assessee had filed return of income for the assessment year 2009-10. Such return was taken in scrutiny by the Assessing Officer. During such scrutiny assessment, the Assessing Officer noticed mismatch between the assessee''s consumption of raw material and output of various drugs manufactured by the assessee. After carrying out detail exercise, the Assessing Officer rejected the assessee''s books and proceeded to examine the possible sale by the assessee outside of the books. The Assessing Officer under this head made an addition of Rs. 96.98 lacs (rounded off). The assessee challenged such addition before the CIT(A) before whom he had produced additional documents. The CIT(A) dismissed the appeal upon which the assessee filed further appeal before the Tribunal. Such appeal was also dismissed. Hence, this appeal. 3. We have heard the learned counsel for the parties. Perusal of the order of the Assessing Officer would show that the assessee had first contended that due to chemical reaction, the manufacturing processes leads to loss of material which depending upon the product is in the range of 3% to 10%. The Assessing Officer, however, noticed that the assessee had consumed raw material of 3,15,096.88 Kgs and claimed to have manufactured 2,27,508 Kgs of finished product. Thus, there was loss of 87588.88 Kgs. 4. This, in terms of the percentage comes to 27.79% as against which the assessee had admitted only loss of 3 to 10%. The Assessing Officer, however, noticed that the assessee had consumed raw material of 3,15,096.88 Kgs and claimed to have manufactured 2,27,508 Kgs of finished product. Thus, there was loss of 87588.88 Kgs. 4. This, in terms of the percentage comes to 27.79% as against which the assessee had admitted only loss of 3 to 10%. The Assessing Officer also took into account the assessee''s further submission that caustic soda and soda flakes utilized in the chemical process would be lost. The Assessing Officer granted the benefit of such loss in vague terms was 10.76%. After considering the overall loss of 6.5% admitted by the assessee, the Assessing Officer believed that there was still shortfall in the sale of the finished product. He, therefore, hold that the assessee''s suppressed production was 4.26%. He made additions accordingly. 5. It can, thus, be seen that the Assessing Officer had carried out minute examination of the material on record. He had held and established that the sale of finished product was below what the assessee ought to have produced and sold even ignoring the production loss and loss of caustic soda and soda flakes during the chemical process. The entire issue was thus, purely factual in nature based on the evidence on record. The CIT(A) and the Tribunal confirmed this view of the Assessing Officer. When two Revenue Authorities and the Tribunal had concurrently decided the issue based on appreciation of evidence on record, we do not find any question of law arising. 6. The assessee''s contention of appropriate opportunity being not given by the Assessing Officer was also considered and rejected by the CIT(A). Perusal of the order of the Assessing Officer would demonstrate that sufficient opportunities were granted. The central issue was only one namely of the production loss viz. a viz. stock shown by the assessee in the books. The assessee had itself produced voluminous evidence. 7. This is not a case where the Assessing Officer had caught the assessee by surprise. There may be minor discrepancy or inaccurate recording of non-essential facts by the CIT(A) and the Tribunal. However, the same would not vitiate the very order or shake the foundation of their orders. In the result, no question of law arises. The appeal is dismissed.