1987 (3) TMI 492

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....der dated 14th March, 1986. The assessee deals in scrap and utensils. There is no dispute regarding the turnover of scrap. The facts are that a diary was seized at the time of survey dated 10th September, 1980. From the diary, it was discovered that the assessee made certain transactions of utensils relating to the assessment year 1978-79, the assessing officer drew the inference that the trans....

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....he assessing officer failed to bring any material on record to draw the inference that the purchases of utensils were made from outside the State. I do not see any legal error in the order of the Tribunal. When the assessing officer initiated proceedings under section 21, it was his duty to show that the assessee made purchases of utensils from outside the State and the turnover of the utensils pu....