9911796707
TMI Blog2004 (8) TMI 320X X X X Extracts X X X X X X X X Extracts X X X X ..... sessee's purchase documents stated lot number, challan number, size, gauge, number of Pattas, number of bundles and total weight, etc., whereas the assessee's sales bills and challans did not contain these details. They mentioned only total weight sold and rate per kg. On query, the partner of the assessee firm, in his statement recorded under section 131 of the IT Act, showed his inability to correlate, from the purchases and sales bills, as to which item purchased at what price, had been sold at what price. 2. The assessee maintained one godown at Bhayander and another at C.P. Tank, Bhuleshwar, Bombay. Out of a total purchase of 10,38,949 kg of SS Pattas, the assessee was found to have received 1,08,311 kg in Bombay. The balance 9,30,637 kg was received at Bhayander. It was further found that the assessee's entire octroi payments were only for receipt of these goods at Bombay and Bhayander. 3. The partner submitted in his statement that on sale, the transport costs, etc., were to be borne by the purchaser. Vide Chartered Accountant's letter dated 3-1-1996 to the Assessing Officer, it was stated that delivery was always given ex-godown. 4. As per the Assessing O ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... at Bhayander was used to square off the cheques received from the hawala operators, after deducting a certain percentage as hawala commission for providing bogus hawala entries. 9. As per the Assessing Officer, the income-tax files of the Category 'A' and Category 'B' parties confirmed that they were merely paper companies. They were in the business of providing hawala entries. So, they fought shy of revealing their sales prices. Their trading accounts showed abnormal percentages of profit, running into lakhs of rupees, from sales of computer hardware, shawls, carpets, etc. These profits were found set off against abnormal percentages of losses from alleged trading in SS Pattas. This left the companies with meagre profits of a few thousand rupees on turnovers of crores of rupees. The Assessing Officer observed that one of the beneficiaries of these hawala companies was Magnum Films, owned by TADA detainees in the Bombay Bomb Blast Case, Samir Hingora and Hanif Kadawalla. 10. As such, the Assessing Officer treated only the sales of 1,10,322 kg in Bombay as genuine. The remaining sales of 8,84,958 kg allegedly made to Bombay parties, were held to be hawala sales. Ou ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t year 1993-94. 13. Vide letter dated 28-2-1997, the learned CIT(A) asked the Assessing Officer to verify the assessee's contentions from the assessment records, which, alongwith the aforesaid written submissions, were enclosed. The Assessing Officer was asked to furnished his comments before 12-3-1997. 13A. Vide letter dated 11-3-1997, the Assessing Officer submitted that the assessee was not available at its Girgaum address; that summons could not be served on the assessee at its 'care of' address, since the Ward Inspector was ill; and that further time of about a month be granted, to enable verification of the genuineness of the assessee's transactions with various purchasers. 14. However, exparte order dated 18-3-1997 was passed by the learned CIT(A), confirming the assessment order. 15. The Assessing Officer submitted Remand Report dated 10-6-1997, including copies of the confirmation of parties. The following parties were stated examined: (1) M/s. Bhavani Industries (2) M/s. Poonam Industries (3) M/s. Shantilal Amratlal and Co. (4) M/s. Ketan Corporation (5) M/s. Jain Enterprises (6) M/s. Sea Gull Exports (7) M/s. Pragati Metal Corporation ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ndependent enquiries from the registrar of companies and the Assessing Officer(s) dealing with the concerned companies' cases and other relevant sources in relation to the above points. 19. The Assessing Officer submitted Remand Report dated 24-2-1999. He stated as follows: "The point-wise comments are as under: (i) The inspector was deputed to enquire with the Registrar of Companies about three companies' registration. He has also visited the concerned IT officer to verify in whose jurisdiction the companies are assessed. He collected information, which is given as under: Name of the company Registration No./date with Registrar of companies Income-tax jurisdiction (a) M/s. Jay Organic Export(P.) Ltd., 128/131,Kazi Sayed St. Raj Bahadur Marg, Mumbai. No. 55221 on 25-1-1990 The case is assessed with ACS(3) at GIR No. 282-J but the returns are not filed since last 6 years. (b) M/s. Ashpon Impex (P.) Ltd. 43/45, 1st Pathan St, 1st fl. Office No. 9, Mumbai. No such Co. is registered As per jurisdiction case should be with ITO Wd. 5(1) but no such Co. appears in the blue book. (c) M/s. Pinky Trading (P.) Ltd. J.V. Soc. M.G. Road, Kandivili(E). No. 62 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ses and sales of the assessee were fully vouched and all the payments received against the sale bills were through account payee cheques only; that the adverse evidence found by the Assessing Officer pertained to the sales made to several parties who appeared to be not doing any genuine business, but were merely acting as name - lenders or hawala operators; that the Assessing Officer referred to the assessment records of three such companies, which depicted abnormal profits shown by these companies from various traders being set off against losses claimed in the trading of SS Pattas; that the Assessing Officer's inference that such name-lenders were merely paper companies and could be doing hawala business, appeared to be plausible; that however, the moot point was as to whether the assessee was also doing hawala business and earning the so-called hawala commission income. 21. The learned CIT(A) observed that in the remand order, the Assessing Officer was specifically asked to point out the basis or evidence to support the assessment of hawala commission income in the hands of the assessee; that the Assessing Officer, in the remand report dated 24-2-1999, merely reiterated par ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... The CIT(A) based his this view on the decision of the Hon'ble Supreme Court in the case of CIT v. Daulatram Rawatmal [1973] 87 ITR 349, wherein, it was held that there should be some direct nexus between the conclusion of fact arrived at by the authority concerned and the primary facts upon which that conclusion is based; and that the use of extraneous and irrelevant material in arriving at the conclusion would vitiate the conclusion of fact. 26. The CIT(A) further observed that the assessment order did not raise any issue of suppression of sales by the assessee. The Assessing Officer who submitted the Remand Report also had not furnished any specific evidence on the point, despite queries raised in the remand order to show whether the assessee had declared its sales at rates lower than the prevailing market rates. The mere fact that the office addresses of most of the purchasing parties were of Mumbai does not lead to the inference that they or their assignees could have taken delivery of the goods from the assessee's Bhayander Godown, particularly when, in all probability, the ultimate buyers were small scale utensils manufacturers situated in the same area. 27. It was ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... er explanation with regard to the sales made. There was a difference in the stocks available in Bombay and the sales made there. The burden was on the assessee to prove stock movement from Bhayander to Bombay. This burden was not discharged. So, the Commissioner (Appeals) wrongly held that delivery of goods could have been taken at Bhayander. 32. The CIT(A) has taken note of the assessee's submission that mere non-availability of some of the purchasers or non-compliance of the summons issued by the Assessing Officer to certain purchasers cannot lead to the conclusion that the assessee had issued bogus sale bills and had thereby earned income through hawala commission. The learned D.R. states that even though time of six months was given for the purpose, the assessee could not produce even a single party who could have vouched for the sales. 33. It was next averred by the learned D.R. that only the financial transactions of the assessee are documented. The learned CIT(A) erred in simply accepting the alleged correctness of the banking transactions, even in the absence of material transactions having been proved. 34. The decision of the Hon'ble Bombay High Court in the cas ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the Companies Ashpon Impex and Pinky Trading did not appear in the Blue Book, whereas Jay Organic had not filed any return since the last six years. The DR points out that the details of Ashpon Impex are at page 60 of the APB. As per these details, the amount of Rs. 1,50,000 was received by the assessee on 23-6-1992, whereas the sale was made on 26-6-1992. So, the payment was received by the assessee prior to the sale having been made. This, as per the learned Departmental Representative, happens only in hawala transactions. 40. The details regarding Jay Ambe and those of Swati have also been pointed out to us by the learned Departmental Representative. It has been averred that in these cases also, the payments were received by the assessee before the sales having been made to the parties. So, no verification was carried out by the learned Commissioner (Appeals). Out of total sales of Rs. 4 crores, sales of Rs. 2.74 crores remained unverified. This amounts to 70 per cent of the total sales. Importantly, these sales were made to parties categorized as A, B and C category parties. The verification done by the Assessing Officer was illegal, as not having been done in accordance with ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... at the end of March, 1993. 50. Mention has also been made of the general trend in the market, as to how material is sold. It is alleged that the practice contended to be followed by the assessee, that is, of taking the payment before the delivery of the goods, is not in conformity with the general business practice of first giving the delivery of the material and thereafter getting receipt of the payments with regard thereto. 51. It is, in this manner, stated that in fact, merely accommodation entries were given by the assessee. In the case of purchases, all quantitative details are available. But in the case of sales, it is not so. Most of the dealings were made in cash. There was more quantity of purchase in the Bhayander Godown and very less quantity in the Bombay Godown. There is wide discrepancy in the stocks available and the sales made. The assessee never produced any of the parties, who are merely paper Companies. They are not dealing in SS Patta, but are, in fact, dealing in computer hardware, carpets, etc. A difference was noted in the stock of SS Patta available in the Bombay Godown. No stock movement is proved to have taken place from the Bhayander Godown of the asse ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f twelve parties appeared before the Assessing Officer in response to the summons issued to them. All of them confirmed the transactions. It was the burden of the Department to prove the allegation that the assessee had merely given accommodation entries. However, it has miserably failed to discharge the said burden. As for the Assessing Officer, he, in the Remand Report, has categorically observed that the sales stood duly verified, and that they were genuine sale transactions, which could not be doubted. 56. Turning to the submission on behalf of the Department that in the case of purchases made by the assessee, all quantitative details were available, whereas it was not so with regard to the sales transacted by it, the learned counsel for the assessee has to contend that the purchases are made in bulk. On the other hand, the sales are made in small quantities. In all the sales bills issued by the assessee, the weight of the commodity sold and the rate at which it is sold, are explicitly mentioned. The assessee duly maintains day to day stock registers and kilogram to kilogram stock registers. These were duly furnished in the assessment proceedings by the assessee. Thus, the ass ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... assessment order, had stated that the parties were not traceable M/s. Ketan Corporation, in remand proceedings, had admitted, in no uncertain terms, that the parties were genuine. 61. With regard to the next contention of the learned Departmental Representative that there was no direct nexus proved and that a difference was noted in the SS Patta stock in the assessee's Bombay Godown, the learned counsel for the assessee has asserted that there is no such difference in the stock. Our attention in this regard is again drawn to the Summary of Movement of Stock in the Bombay and Bhayander Godowns of the assessee, for the period 1-4-1992 to 31-3-1993. It is submitted that t he details of stock tally and movement of stock were furnished by the assessee before the Authorities. 62. The Departmental Representative has also averred that no stock movement took place from the Bhayander Godown of the assessee to its Bombay Godown and that this clearly indicates that the transactions entered into by the assessee were nothing but hawala transactions. To this averment, the response of the learned counsel for the assessee before us has been that a day to day and kilogram to kilogram stock ta ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... fied the books of the assessee and the orders of the earlier year. It was only when the Assessing Officer was found to have categorically stated in his remand report that there was no evidence against the assessee, that the learned Commissioner (Appeals) ordered the deletion of the additions. The learned Commissioner (Appeals) also noted that for the assessment year 1992-93, the matter had been re-opened and that subsequently, the Assessing Officer had himself accepted the sales made by the assessee to be entirely genuine. The learned counsel for the assessee has also filed on record before us copies of the said order. 67. Then, replying to the argument of the learned Departmental Representative, that the learned Commissioner (Appeals) has gone wrong in placing reliance on the order of the learned CIT(A) in the case of Sarvottam Metals, to hold in favour of the assessee, the learned counsel for the assessee has submitted that in that case, the Tribunal, vide their order dated 24-4-2002, in ITA Nos. 1962 and 1063/Mum./95, for assessment years 1988-89 and 1990-91, has decided in favour of the assessee. 68. Regarding the assertion that there is no mention of any details in the deliv ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tions entered into by the assessee. It has been stressed that the details of the parties from whom the sales transactions were confirmed in favour of the assessee by the Assessing Officer, amounted to a sum of two crore and forty seven lakh rupees. A list in this regard has been enclosed by the assessee at page 72 of the assessee's paper-book. 71. The learned Departmental Representative has also alleged that it is not palatable that the assessee received payment in advance, whereas the material was supplied to the customers by the assessee subsequently. To this, the learned counsel for the assessee has to submit that as a prudent businessman, it insisted on advance on account payment of the sales proceeds from its purchaser parties and that it was only after the cheques got cleared by the banks that the material was allowed to be lifted by the said purchasers from the godown of the assessee. That since the money was received in advance, id est, before the handing over of the delivery of the material by the assessee to its customers, the profit margin earned by the assessee was very low goes miles to prove that such was the method of doing business adopted by the present assess ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... lorry receipt proving transportation of SS Patta from the Bhayander Godown of the assessee to its Bombay Godown, speaks against the assessee, the learned counsel for the assessee has said that all purchases made by the assessee from Jodhpur for its Bombay Godown are supported duly by octroi payment receipts along with Forms B, which Forms are proof that material had, in fact, come to Bombay, as also the reference of the transporter who transported the material in question to Bombay. Further, it has been stated that all the purchases made by the assessee from Jodhpur for its Bhayander Godown stand duly supported by Mira Bhayander Nagar Parishad receipts with regard to entry tax, along with the reference of the transporter having made the transport to Bhayander from Jodhpur. It has been submitted that the assessee has not transferred the material either from Bhayander to Bombay, or from Bombay to Bhayander. In accordance with the terms of the contract, specific goods were to be delivered at Bhayander and specific goods were to be delivered in Bombay. It was so done. No evidence to the contrary has been produced by the Department. Just wild allegations sans any evidentiary support of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... red. It has been contended that this assertion may well be verified bill-wise and challan-wise, as per the stock register produced by the assessee. It is pleaded that there exists a difference of not even a kilogram and thus, the observation of the Assessing Officer in the assessment order has been made without as much as verifying the records of the assessee, baselessly, merely on presumptions and assumptions. This has rightly been rectified by the learned Commissioner (Appeals). 75A. With regard to the argument on behalf of the Department that the assessee was not in possession of even a single kilogram of stock in Bombay, at the end of the month of March, 1993, the learned counsel for the assessee has submitted that the last lot of material was received by the assessee in Bombay in the month of March, 1993. This material was sold before the end of March. It was therefore, that the assessee was left with no stock of material at the end of the month of March, 1993, in its Bombay Godown. Later, the assessee decided to close down its business. This came about in the Month of June, 1993. Thus, it stands amply and cogently proved that this was the reason why the assessee did not keep ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... uine. M/s. Choudhary Industries filed their confirmation letter with regard to the genuineness of the transactions, vide their letter dated 18-6-1997. It was only because the Assessing Officer did not find any defects in the books of account maintained by the assessee, that the books were not rejected. It was the burden of the Revenue to prove that the transactions entered into by the assessee were hawala transactions. However, the Revenue utterly failed to do so. No addition can be made just on the basis of presumptions. In the face of quantitative tally having been furnished, even if the purchaser parties are not traceable, no addition can legally be made. At that, the learned counsel for the assessee has pleaded for the order of the learned Commissioner (Appeals) to be upheld. 78. We have heard the parties and have perused the material on record. The issue to be adjudicated upon here is as to whether the assessee earned hawala commission. 79. Of the parties categorized by the Assessing Officer as 'A', 'B' and 'C category parties, the first three of the 'C' category parties confirmed having received 1,55,985 kilograms of SS Patta from the assessee in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... a Registered Office at some other place, as is the case with many Companies. This, as per the assessee, did not, as of necessity lead to the conclusion that M/s. Ashpon Impex (P.) Ltd. was not registered as a company at all, throughout India. In any case, non-availability of the said company does not lead to an invariable conclusion against the veracity of the stand taken by the assessee. The assessee also made mention of its letter dated 12-8-1998, addressed to the learned Commissioner (Appeals), wherein the assessee had asserted that all the payments had been received by it through 'Account Payee' cheques only. In that letter, the assessee stated that it makes sales only against payments by Account Payee cheques; during the financial year 1992-93, sales had been made by the assessee to one hundred and ninety-eight parties; the only way the assessee could ascertain the creditworthiness of the parties was by ensuring that the delivery of the material was given to them only when the cheques had been cleared; in this manner, even if the cheques had not been cleared by the banks, the assessee had the protection of the Negotiable Instruments Act in his Assessment Order dated 2 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... by the assessee, that the Income-tax Officer had found as per his Report dated 10-6-1997, that the business of the assessee had been found to be a genuine one. The assessee further stated in respect of the Assessing Officer having mentioned in his Remand Report regarding the quantitative movement of stock, repeating the observations contained in the assessment order, that he was totally wrong. It was stressed that the stock tally of the assessee was entirely correct and that there was no discrepancy in the Bombay and Bhayander Godowns of the assessee. The assessee pointed out that the Assessing Officer had himself admitted that there was no evidence concerning any rate of cash sales presumably having been made by the assessee. It was also submitted that in the order seeking Remand Report, the learned Commissioner (Appeals) had asked for any evidence, if available, regarding gross profit earned at a higher rate by other assessees. However, the Assessing Officer had not given any such instance of any gross profit having been earned at a higher rate by any other assessee. In fact the Assessing Officer had pointed out that no addition had been made on account of gross profit ratio. The ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... only and only by way of Account Payee cheques. This manner of transacting business is but in consonance with general prudent business acumen. This mode ensures to the assessee protection under the law, id est, under the Negotiable Instruments Act. In case a cheque bounces, the payee is liable under the said Art and the business interest of the assessee stands duly protected. Too, this medium of payment is adopted since through it, the assessee can well ascertain the creditworthiness of the purchaser. Delivery of the material is only given once the payment through Account Payee cheque is cleared by the bank. In fact, there is no other effective way to ensure that the purchasing party is solvent or creditworthy. Also, no other evidence has been brought to suggest that the purchasing parties of the assessee were bogus or nonexistent parties. So far as regards the onus on the assessee, it is but an onus and not a burden, in the sense that the assessee is required to reasonably verify the genuineness of its purchaser parties, which onus stands duly discharged by showing that all its payments were received through Account Payee cheques. The assessee even produced the pay-in-slips and ba ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... akes were pointed out by the Assessing Officer in these records maintained by the assessee. It is on record that the business of the assessee is dealing in SS Patta. This Patta is of the same gauge. It is not acquired by the assessee as per the requirements of the customers. It is sold as per the stock available with the assessee. It has also come on record that the purchaser parties take the delivery of the material themselves from the godown of the assessee. The Patta is stored in the godowns as and when it is acquired and is mixed with the existing stock. The delivery challans mention as to from where the delivery was taken, the description of the material, the weight of the goods delivered, the rates and the serial No. At the top of each Challan, 'Despatch through-Direct' is mentioned. Since all the deliveries were taken ex-godown, neither lorry receipt, nor date thereof has been shown. Further, all the sales bills are serially numbered. They contain the reference of all the respective delivery challans. In case the books maintained by the assessee had been found to be not in order, there was no stopping the Assessing Officer to question this. However, such a supposed i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ies, as alleged. The impugned order was passed after having taken into consideration all the aforesaid details. So, it cannot be said that there was no proper explanation regarding the sales made by the assessee. Rather, as observed above, the transactions were admitted as genuine and were found to be so. 88. Coming to the assertion that merely accommodation entries were given by the assessee, the stand of the learned DR has been that the learned CIT(A) has merely taken into consideration the financial transactions of the assessee without there finding any support from evidence in the shape of material transaction having been proved to have been actually gone into by the assessee. However, the department, as observed, has not been able to prove the fact that the payment for the sales made by the assessee had been received only by way of Account Payee cheques, and through no other mode. That this process is the accepted method of transacting business, has not been challenged. No mala fide have been alleged against the assessee in this regard. The allegation that in fact, cash sales were made, remains what it is just a bald allegation, unsubstantiated by any material on record, in t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the period from 1-4-1992 to 31-3-1993, was produced before the Assessing Officer as well as CIT(A). They are also before us, at pages 52 to 54 of the APB. These details have not been disputed. Therefore, the movement of stock, as pleaded by the assessee, stand proved. Still further, the factual situation explained by the assessee, has not been controverted. As such, there is no force in the argument that there is more quantity of purchase from the Bhayander Godown of the assessee as compared to that made from the Bombay Godown and it cannot be said that the allegation incriminates the assessee. 90. Regarding the allegation that the assessee was not able to produce any purchaser party could have testified the veracity of the sales made by the assessee, even though a long span of six months was afforded to the assessee for the purpose and that it was wrong to conclude as has been done by the learned CIT(A) that, mere non-availability of some of the purchasers or non-compliance of the summons issued by the Assessing Officer to certain purchasers, cannot lead, to the result that the assessee had issued bogus bills, proving that the assessee had earned income through hawala commission ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... erence in rates exists because the locus of the two instances was distinct. One sale was in Bombay, whereas the other was at Bhayander. So, the alleged difference in the rates of sales is a difference between equals and un-equals. The said differences have not been validly explained by the department. We do not agree with the department on this issue also. 92A. Coming to the sales tax order passed under section 33(3) of the Bombay Sales Tax Act, the department has not been able to show any parity between such order and one passed under section 143(1)(a) of the IT Act. A perusal of this order reveals that the books of account were seen by the Sales Tax Officer. This order has been passed under section 33(3) of the Bombay Sales Tax Act, 1959. The said section reads as follows: "S.33 Assessment of taxes (3). - If the Commissioner is not satisfied that the returns furnished in respect of any period are correct and complete, and he thinks it, necessary to require the presence of the dealer of the productions of further evidence, he shall serve on such dealer in the prescribed manner a notice requiring him on a date and at a place specified therein, either to attend and produce or cau ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... stock. The delivery challans with regard to the sales are with the assessee. All the three "C" category parties confirmed before the Assessing Officer that they had though taken delivery of stock from the Bhayander and Bombay Godowns of the assessee, this was done, they stated, by way of all having countersigned the respective delivery challans. All deliveries, without exception, were taken by the purchasers ex-godown of the assessee, as agreed between the assessee and the parties. Moreover, all the sales invoices issued by the assessee to these purchaser parties contained the mention of the delivery challans. So, the alleged difference was imaginary and was lawfully declined by the learned CIT(A). 95. Non-availability of any stock with the assessee in its Bombay Godown, at the end of March 1993 is also of no avail to the department. The last lot of stock had been sold off. Thereafter, no stock was stored, since the assessee contemplated shutting down of its business, which finally came about in the month of June 1993. 96. So far as the alleged general market trend of carrying on business, as discussed, the department cannot dictate as to how an assessee is to carry on its busine ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... that the assessee had produced enough evidence to establish that the sales were genuine. In the case before us also, in our view, the assessee has produced enough evidence to establish that the sales were genuine. Therefore, this order furthers the case of the assessee. 99.2 Similarly, the decision of the Mumbai Tribunal in the case of M/s. Sunder Steel Industries, in ITA No. 471/B/94, for assessment year 1990-91 vide order dated 18-8-2003, copies whereof have been filed on record, is in favour of the assessee. 100. Further, the assessment order for the assessment year 1992-93, i.e., the immediately preceding assessment year, has also been placed on record. This order finds mention that the goods which were received by the assessee from Jodhpur were supported by lorry receipt and octroi paid challans. The assessee was also paying sales tax of Rs. 1,51,672. The assessee also produced books of account, comprising cash books, ledger and sales and purchase registers, which were duly verified. Notices to the purchasers, i.e., M/s. Mukesh Traders, Rajendra and M/s. Sea Gull Exports, M/s. Poonam Industries, M/s. Shantilal Amritlal and Co. were issued. The genuineness of the transaction ..... X X X X Extracts X X X X X X X X Extracts X X X X
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