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1995 (9) TMI 364

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..... e orders: (exhibit P3) of the Intelligence Officer, Squad No. I, Alappuzha; (exhibit P5) the first revisional order of the Deputy Commissioner, Agricultural Income-tax and Sales Tax, Alappuzha and also the second revisional order (exhibit P8) of the Member, Board of Revenue (Taxes), Trivandrum. 2.. The last impugned order records that what was urged that a reasonable opportunity of being heard i .....

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..... he order of the first revisional authority (exhibit P5) is considered the observations at page 35 (exhibit P5) would show that on September 20, 1993 a petition was made and the Intelligence Officer has granted time up to October 4, 1993. It is also recorded that the petitioner filed a detailed reply along with the stock reconciliation statement related to all the items recorded in the shop inspect .....

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..... the petitioner did not produce the day book initially and has been particular to place on record that there are no manufacturing accounts at the factory. He has considered the position on the basis of elements specifically violative of the stock material, leading to the observation that the accounts maintained by the dealer are incorrect and incomplete. In fact this conclusion floats on the sur .....

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..... way that the purchases, stock and sale would not reflect in the books of accounts. 4.. Learned counsel submitted that reasonable opportunity would have to be understood as an opportunity to the petitioner to be present for explaining the position. Reading the petition in the light of the conclusions recorded by the three authorities, on facts it is not possible to exercise powers under article 2 .....

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