Private notebook entries need corroboration before they can support a finished-goods clearance demand.

Private notebook entries maintained by a labour contractor could not, by themselves, be treated as clearance figures of finished goods to sustain a demand. The presumption based on those entries was found impermissible because no corroborating, reliable or independent evidence supported the allegation. As the show cause notice rested on an unsound evidentiary basis, the revenue's contention was rejected, the assessee's stand was accepted, and the appeal was dismissed.

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Issues: Whether entries in a private notebook maintained by a labour contractor, without corroborating independent evidence, could be treated as clearance figures of finished goods for the purpose of sustaining the demand.

Analysis: The presumption drawn from the private notebook entries was held to be impermissible in the absence of corroborating, reliable and independent evidence. The basis of the show cause notice was therefore found to be misplaced, and the revenue's contention was rejected.

Conclusion: The challenge failed and the assessee's stand was accepted; the appeal was dismissed.

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