Job-work conversion charges and ink-cost evidence required fresh verification, with the time-bar plea also to be examined on remand.

Evidence supporting inclusion of ink cost in job-work conversion charges required fresh verification, as the Chartered Accountant's certificate stated that the charges covered ink, wages, salaries, overheads and profit margin, and the record showed examination of the books and documents of the sub-contractors and the assessee. Rejection of that evidence for absence of a separate ink-cost split-up was treated as a matter for further inquiry, and the appellants were to be given an opportunity to produce supporting material. The plea of time bar was also directed to be examined in the de novo proceedings. The matter was remanded to the original authority for fresh consideration.

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Issues: Whether the demand required fresh examination in de novo proceedings in view of the evidence produced regarding inclusion of ink cost and the need to consider the time-bar plea.

Analysis: The certificate of the Chartered Accountant stated that the conversion charges paid to the job workers included the cost of ink, wages, salaries, overheads and profit margin, and the record indicated that the verification was based on the books and documents of the sub-contractors and the assessee. The rejection of the evidence for want of a split-up of ink cost was found to be a matter capable of further verification, and the appellants were to be given an opportunity to produce supporting material. The plea of time bar was also directed to be examined in the de novo proceedings.

Conclusion: The matter was remanded to the original authority for fresh consideration with a reasonable opportunity to the appellants to substantiate their case.

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