Devan Ramachandran, J.

1. The appellant – which is stated to be a firm, engaged in the retail sale of liquor, under valid licence obtained as per the Abkari Act - asserts that, in the year 2016–17, some stock of beer was damaged, its date of expiry has elapsed; and, hence, that the same was destroyed as per law. They say that they had prepared their books of accounts, including Profit and Loss Accounts, showing the value of the damaged stock; but that, when assessment was made by the Assessing Authority under the Kerala General Sales Tax Act, 1963 (‘KGST Act’), this was disallowed, which constrained them to move the First Appellate Authority, - which found against them; and consequently the Kerala Agricultural Income Tax and Sales Tax Appellate Tribunal, Additional Bench, Ernakulam ‘Tribunal’, for short), but to be again answered against them.

2. The appellant contends that the findings of the Appellate Authority and that of the learned Tribunal are in error; and thus in Revision before us.

3. Sri.Abraham K.J. - learned counsel for the petitioner, submitted that two questions of law arise in this case, namely, (i) whether the Tax Authorities could have reckoned the damaged stock also for the purpose of assessment against his client; and secondly, (ii) if the books of account could have been rejected, without citing any cogent reason.

4. We notice that the questions of law framed by the Revision Petitioner in the memorandum of this petition align with the afore submissions of their learned counsel; but, are of the firm view that, in the factual circumstances presented, it is unnecessary for this Court to answer them, or even to admit this Revision.

5. We will presently state the reasons that persuade us to say so.

6. As indited above, it is the case of the petitioner that a certain stock of beer was damaged in the year 2016, because its expiry date had passed; and therefore, that its value was written off in their books of accounts, after the same had been destroyed as per law.

7. Pertinently, the petitioner relies solely on Annexure-D letter dated 15.10.2025 - issued to them by the Circle Inspector of Excise, Ernakulam, in substantiation of their assertion that the stock in question had been destroyed by them in the year 2016. This letter – indubitably issued in response to a letter by the appellant dated 14.10.2025 - only records the established legal position that, as per the Food Safety and Standard (Labelling and Display) Regulations, 2020, it is mandatory that the expiry date of the commodity be shown on the bottle; and that, if it becomes unsafe for use, it be destroyed after completing the legal formalities.

8. What is virtually relevant from Annexure-D is that it is not a Certificate issued by the Excise to the effect that any stock – much less the one in question – had been destroyed as per law, for the reason that its expiry date has crossed, in the year 2016 or 2017. On the other hand, its contents are mere statements, based on the applicable law; but specifically stating that any damaged stock could be destroyed only after following the “legal formalities” (sic).

9. Therefore, even if the appellant is to obtain any support from Annexure-D, they must prove both that the stock they refer to had become unusable, with the date of expiry having reached; and also that it had been destroyed in the manner mandated in law. It is only then, could they seek that their book of accounts be accepted.

10. Interestingly, the appellant seems fully cognizant of the above twin requisites, which is fully reflected from the submissions of their learned counsel - Sri.Abraham K.J., who maintained before us that the stock had been destroyed in the year 2016-17 in the presence of the Officers of the Excise, and as per their directions; to then incredulously assert that his client had been refused to be given any certificate or record of the same by the Authorities, as required in law.

11. Leave aside that the afore imputation is so far-fetched that it cannot be countenanced at all, even if it were to be taken as true, it would enure no benefit to the petitioner, since, like every taxing State, the ‘KGST Act’ requires implicit compliance. This is more so, when the commodity involved is liquor.

12. It is without necessity of expatiation that, if the value of any stock – even with its expiry date crossed - is to be deducted from the returns of the appellant, it will have to be cogently and firmly established that it was either returned to the Authorities; or destroyed as per law, following the mandate of the applicable statutory Scheme.

13. When the petitioner does not, even whisperingly, have a case that either the stock in question had been returned to the Authorities; and when they have failed adjectly to prove that any such had been destroyed in accordance with law, the impugned orders become irreproachable, since the disputed sum deserves to be fully added to their returns, without any disallowance on that account.

14. In such factual backdrop, one cannot find any question of law - much less a substantial one – to be attracted for our consideration or answer.

This Revision Petition have deserved no admission; and is consequently dismissed.