TMI Blog2022 (3) TMI 747X X X X Extracts X X X X X X X X Extracts X X X X ..... . Against the quantity mentioned against all the three items of stock of finished goods, it is not explained how the said quantity has been arrived at. Thus, evidently, it is a case of eye estimation. Further, it is found that there is only an apparent difference of about 8 MT in the three items, which is insignificant, not requiring any adverse inference. The show cause notice is wholly mis-co ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... statement of stock verification and comparing it with the RG-I figures, shortage in the stock of three items of finished goods were worked out and accordingly, a show cause notice dated 10.11.2005 was issued invoking extended period of limitation. In the show cause notice, it is observed that the Director of the appellant filed a written representation dated 15.01.2001 (within a week), wherein it ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... uty of ₹ 6,15,645/- be demanded along with penalty and interest. 5. Upon considering the arguments of both the sides and on going through the Panchnama dated 10.01.2001, I find that there is no calculation sheet. Against the quantity mentioned against all the three items of stock of finished goods, it is not explained how the said quantity has been arrived at. Thus, evidently, it is a cas ..... X X X X Extracts X X X X X X X X Extracts X X X X
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