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2009 (4) TMI 837 - MADRAS HIGH COURTReopening of assessment - Held that:- The only reason for the revenue to reopen the assessment was that there was a huge purchase of oil. This has been explained by the assessee, that those oils were manufactured out of the groundnut purchased from the agriculturists and the bought vouchers were also produced while framing the original accounts and they were accepted. The reason now stated for reopening the assessment is the bought vouchers did not contain the complete details of the persons from whom the assessee purchased the groundnut. When the assessee is purchasing a small quantity of groundnut from the agriculturists it may not be possible for them to record the entire details as to the name, address and the village from which the agriculturists hail and the extent of the land he is owning or the source of purchase such as whether the groundnut has been acquired by him as a cooly for working in the groundnut field or he is owning a land in wahich groundnut is cultivated. In addition to that, the idea conceived by the revenue that all these purchases were crushed by the sister concern, which was also laid in the very same campus is also defeated by the meter reading of the sister concern, which is owning a crushing unit. There is virtually no electrical consumption. In addition to that it is also on record that the said sister concern has stopped its activities several years ago and that stoppage of the activities has also been informed to the Department. Revision dismissed.
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