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2019 (10) TMI 41 - ALLAHABAD HIGH COURTGrant of reduction in tax - rejection of books of accounts of revisionist - HELD THAT:- Though it is true that the Tribunal has first recorded findings to the effect that the assessee-manager/employee-Mahendra Kumar Pandey had not signed on the survey report and it did not appear to the Tribunal that he had made statement at the time of survey and further no physical verification of the stock was made yet it has also been inferred by the Tribunal that there was vast discrepancy in the disclosed stock of 'chhuwara' being 7,147.38 kgs disclosed in the books and that noted by the survey authority at 10,250 kgs. In that regard, the Tribunal took note of the fact that the number of bags had been counted being 175 - Keeping in mind that and other factors that remained undenied, the Tribunal itself made an estimation of the undisclosed stock of that commodity at 2000 kgs. In the facts of the present case, the Tribunal itself found that there were 2000 ksgs of 'chhuwara' that had not been accounted for. Besides that, there was material in the shape of loose parchas of 'wastage' and 'dibbi'. Therefore, it cannot be said that there was no basis for the estimation made by the Tribunal. Revision dismissed.
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