SUNEET KUMAR,J. - (1.) Heard learned counsel for the parties.
(2.) The revision pertains to assessment year 2002-03 arising from the order dated 17 December 2016 passed by the Commercial Tax Tribunal, Allahabad Bench, Allahabad.
(3.) The revisionist is, inter alia, engaged in the business of manufacture and sale of chemically treated ozonised flour (aata, maida and suji). The dealer was assessed on best judgment assessment. The tax liability was determined under Section 3G of the Trade Tax Act, 1948. The dealer assailed the assessment order, however the Tribunal vide order dated 25 August 2012 remitted the matter to the assessing authority on a limited question as to whether the dealer had ozonised chemical treatment as alleged pursuant to the bills of purchase from a supplier at Kolkatta. Pursuant thereof, the dealer was assessed for the period of 25 August 2002 to 31 March 2003. The total sales in value was accepted but the Tax assessing authority rejected the total purchase in value of wheat for the reason that difference between the sales turnover and purchase turnover in monetary terms was very high almost 400%. The order of the assessing authority was affirmed by the first appellate, as well as, second appellate authority.;