2014 (2) TMI 1160

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....e manufacturing and export of handicraft, handloom and leather items. A survey action u/s 133A was conducted on 21.2.2007 on the following three premises of the assessee: a. M/s Sharma Industries Pvt. Ltd., C-28, Site-C, UPSIDC, Industrial Area, Sikandra, Agra. b. M/s Sharma Industries Pvt. Ltd., C-24, Site-C, UPSIDC, Industrial Area, Sikandra, Agra. c. 23-24, India Exposition Mart, F-59A, Knowledge Park, Greater Noida. 3. During the course of survey action, inventory was taken at the following places: a. 23-24, India Exposition Mart, F-59A, Knowledge Park, Greater Noida. b. M/s Sharma Industries Pvt. Ltd., C-28, Site-C, UPSIDC, Industrial Area, Sikandra, Agra. 4. The stock was valued at Rs. 6,57,613/- by the survey tea....

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....er. d. In the quantities details column of tax audit report the auditor gives information with respect to certain items only whereas the assessee being a manufacturer of various handicrafts items should also provide raw material details. e. During the course of assessment proceedings the authorized representative has filed copy of stock register which has been prepared after the survey and is based on sale and purchase bill. f. This stock register shows that assessee has not conducted any business after the date of survey and the stock as per books is shown at Rs. 39,93,069/- g. If the above figure of stock is compared with the physical stock found during the survey which has been valued at about Rs. 13,15,220/-, there will be a....

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....used the relevant material on record. It has been noticed above that the assessee is a manufacturer and exporter of handicraft, handloom and leather items. It has remained uncontroverted before us that the tax audit report did not mention that the assessee manufactured any stock register; the quantitative details given in tax audit report were only in respect of certain trading items and not raw materials and finished product manufactured by the assessee. It became evident during the course of survey that the assessee did not maintain any stock register. The stock register produced before the A.O were admittedly prepare after the date of survey which were again limited to sale and purchase bills only. The above factors amply prove that the ....