Sales suppression not proved where seized slips and stock variation were reconciled with job-work records and supporting documents.

Seized slips, book marked 'A', stock variation and a recorded statement did not establish sales suppression where the surrounding records consistently supported the assessee's job-work activity. Order forms, delivery bills, receipt vouchers, issue vouchers and labour bills, together with the reconciliation of the seized entries, showed that the names noted related to main workers and sub-artisans. The Revenue produced no material proving actual sales, purchase of jewellery or receipt of sale consideration, and the stock difference was explained as sample jewellery entrusted for manufacture. On this evidence-based appreciation, the Tribunal's deletion of the assessed turnover and refusal of remand were sustained.

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Issues: Whether the Tribunal was justified in deleting the assessed turnover and refusing remand on the basis that the seized slips, book marked 'A', stock variation and recorded statement did not establish sales suppression, but only job work.

Analysis: The assessee had consistently been treated in the earlier and later assessment years as carrying on job work, and the records such as order forms, delivery bills, receipt vouchers, issue vouchers and labour bills supported that position. The entries in the seized materials were reconciled with the surrounding documentary evidence and the names noted therein were shown to relate to main workers and sub-artisans. The Revenue did not produce material to establish actual sales or purchase of jewellery or receipt of sale consideration. The alleged stock variation was also explained as sample jewellery entrusted by dealers for manufacture on their behalf. The findings turned on appreciation of evidence and did not disclose any perversity warranting interference.

Conclusion: The Tribunal was correct in holding that the materials did not prove sales suppression and in setting aside the remand. The Revenue's revisions failed.

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