as rice sludge oil, groundnut sludge oil, sunflower sludge oil rice filtered wax, sunflower filter wax. They are importing Raw Sunflower Oil and Raw Palm Kernel Oil . All above items are purchased by them from both local and interstate market and diverting towards the sales of local and interstate needs. Considering the practical requirement of all these different categories, it is very clear that all these different oils have to be stored in different containers. Further, they are undergoing manufacturing process to finished products, which are in equal number of categories and they also need to be stored in different containers. Without these brief arrangement of storage, the monitoring and maintenance of quantum wise disposal through different channel of sales catering local and interstate market needs. From their report and documents submitted, it is clear that they are maintaining only five containers tanks which cannot cater the above needs. It has no clarity to understand how such a vast number of line of products can be channelized with five number of tanks to identify the flow of different and connected inflow and outflow. They are contenting that they are maintaining different stock register for different category of products, which is not understood how it is possible without parallel different storage amenity arrangements. Moreover, among their documents, they have not produced any day-to-day inward and outward supply of materials from their Input to manufacturing, Manufacturing to finished goods, Input to direct supply, Finished goods to supply, without which the statement that maintaining different stock register is not scientific and acceptable. Hence, with a clear examination of their documents, it is clearly noticed that the stock details, what they have produced, is not reflecting the fact on their flow of utilization of inputs to outputs on different channels. In view of this fact, the contention put forth by them is not sustainable and thereby, it is overruled. Therefore, the proposal for reversal of credit u/s.19(4): on the proportionate basis, hereby confirmed. The reversal amount is worked out as detailed below:
