ASHWANI KUMAR MISHRA,J. - (1.) Submission is that assessee had produced relevant materials to show the transaction, and had also offered to produce all other relevant books of account, in case it was required. It is contended that the assessee is a registered reputed dealer, which is having business of a high magnitude, and it was not possible to produce the entire books of account. It is also stated that materials to support the transaction, brought on record, have not been looked into.
(2.) Learned Standing Counsel, on the other hand, submits that in case the documents were voluminous, it was open for the assessee to have moved an application for the records to have been inspected, and on such ground, the order of the authorities could not be challenged.
(3.) From the materials placed, this Court finds that the assessee has in fact produced various records including the ledger, relevant sales register, excise invoices and copy of transporter GR/duty etc., but the same have not been looked into by the authorities, on the ground that books of account of have not been produced. In the opinion of the Court, once such supporting documents had been presented before authorities, and the assessee had already offered to produce other records, if required, as it was voluminous, it was open for the authorities to have directed the assessee to produce other materials or inspect the records. Even otherwise, the documents, which have been produced, have not been examined, nor there is any finding that such materials are not reliable.;