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1992 (9) TMI 338

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..... dditional Bench) at Madras in three appeals before it, relating to three assessment years 1986-87, 1987-88 and 1988-89. The assessees are dealers in jewellery. The place of their business was inspected on August 31, 1988 and on the basis of the incriminating documents recovered and the consequent inference that one goldsmith S.L. Rajaprathinithi was executing orders of the assessee's customers, th .....

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..... ain an addition to the extent of four times was made and the total suppression was arrived at Rs. 2,92,545. He also levied penalty to the extent of Rs. 5,703. 2.. The appeals preferred against the order of the assessing officer by the assessees, were also dismissed by the Appellate Assistant Commissioner. 3.. The abovesaid second appeals filed by the assessees before the Tribunal were partly a .....

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..... order: "The contention of the appellants is that the recovered slips do not belong to the appellants and they belong only to Thiru S.L. Rajaprathinithi a goldsmith. It is seen from the statement given by one Thiru P. Subramaniam, authorised representative, that Thiru S.L. Rajaprathinithi, a goldsmith, who is having a workshop in the same place of business of the appellants doing labour work for .....

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..... proved that the goldsmith is doing labour work for the appellants it is obvious that the ornaments have been manufactured for labour only. Under these circumstances we have no hesitation to hold that the goldsmith is doing labour work only for the appellants and sister concern and not to outsiders and the goods manufactured relate to the appellants only." 5.. Since thus the nexus between the abo .....

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