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Your Buyers' Guide To Pewter Products
From the Middle Ages until the 18th and 19th centuries, pewter products were very common. During this time, there was a mass production of glass products that replaced pewter in everyday life. Pewter was just about gone when it gradually stopped being used by 1850. By the 20th Century, the craft of making pewter products was brought back into existence. Today, pewter is used in decorative objects, collectible statuettes, figurines, and so forth.
Quality of Pewter Products
The high quality pewter items today contain around 97 percent tin and are 100 percent lead-free. It is completely safe for foods and is easy to care for.
Types of Pewter Products Available
The types of pewter products available are endless. Here are just a few: vases, figurines, mugs, plates, water pitches, goblets, belt buckles, and jewelry.
Brand Names Available
There are many brand names of pewter available as well, such as Siskiyou, Shirley, Selangon, and Heritage.
Giving Pewter as Gifts
Pewter items make such special gifts because the person receiving the gift will have these items for such a long time. Also, pewter does not require any special care. This will make the gift even more enjoyable.
For that special female in your life, there are a wide variety of gift ideas. You have your choice of fine-crafted jewelry, key ring with her favorite dog, and even beautiful photo frames to show off her grandchildren. You can also begin a new tradition every year by giving her a collectible ornament. Another great gift idea for that special lady is pewter tableware. A touch of delight can be added to any table with a variety of pewter tableware.
And for that special male in your life, whether he is an NFL, MBL, NCAA or NASCAR fan, there are so many unique items to choose from. Giving him a pewter belt buckle would be the perfect way to let him show off his favorite sports team. For the avid golfer, he would enjoy the can cooler or the tankard. He could keep these as collectibles or use them for personal use.
Just remember, you can do your shopping online for that special pewter gift. While there, you may see some items you have dreamed of having for yourself such as a natural stone fountain, a beautiful etched glass mirror or that fascinating neon clock. Click online today and order the unique pewter gift that will be cherished for a lifetime.
To learn more about subjects like pewter please visit the web site at: http://foryourhome.biz/
For more information and informative related articles and links about this subject matter and content, please visit Majon's Gifts | Gift Ideas | Gift Shops directory: http://www.majon.com/directory/gifts-gift-ideas-gift-shops.
About the Author
+Chris Robertson is a published author of Majon International. All Rights Reserved. Copyright 2014 (Tue Feb 27 2007) Majon International. Majon International is one of the worlds MOST popular internet marketing and internet advertising companies on the web. Visit their main business resource internet marketing web site at: http://www.majon.com


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Tweets from @TBHomeTeam/writers
MORE from our HomeTeam writers.
Fri. February 8, 2013 | Andy Warrener
LUTZ — Steinbrenner continued its shooting gallery playoff run by running up four goals Friday on Ocala Forest.
Only this time it took two overtime periods and Forest matched Steinbrenner's scoring frenzy step-for-step until the final three minutes of the second overtime, when senior captain Derek Gebhard cleaned up a ball played into the box by senior Enrique Barboto. The Warriors' golden goal earned them a 4-3 victory and a spot in the Class 4A state final, their first state finals appearance.
"When he (Barboto) hit it I was thinking, 'Where did it go?' " Gebhard said. "Then it landed right on my thigh and I knew I had a chance to play it short and I finished it."
It was an unbelievable finish to a game in an unbelievable playoff run for the Warriors that has seen them score 20 goals in four games.
"We're just a strong, attacking team," senior captain Jason Collister said. "We feel like if any team can do it (win a state title), it's us."
The Warriors seemed to pick up where they left off Tuesday, coming out and pressing the action. Early shot attempts were either thwarted by Wildcat goalkeeper Lex Craggs (11 saves) or went wide or high.
"Their goalkeeper and defense were phenomenal," Warriors coach Chad Ebright said. "They won a lot of games 1-0 so you knew they had good defense."
After falling behind 1-0, the shots started to fall for Steinbrenner. In the ninth minute of the first half, Collister knocked in a Blake Wilson header from a Barboto free kick that tied the game. Three minutes later, Wilson penetrated deep into Wildcat territory and passed it off to junior Austin Labban, who pounded it far post to go up 2-1. Barely a minute later, Collister got on a solo fastbreak through the Wildcats' back line and was one-on-one with the keeper. Craggs had no chance as Collister knocked it in to put the Warriors up 3-1.
Nine minutes into the second half it was 3-2 Warriors. Forest's Jesse Nieman stepped up his game and in the 12th minute battled through three Steinbrenner defenders, tipped the ball up to himself and pounded it far post.
The first regulation expired in a 3-3 tie.
Steinbrenner committed 30 fouls and received three yellow cards to Forests 16 fouls and two yellow cards. The Warriors out-shot the Wildcats 20-6. A foul and a shot set up the winner.
With three minutes left before heading to penalty kicks, Labban was fouled hard by Sebastian Del Rio. Del Rio received a yellow card and Steinbrenner received a free kick from about 25 yards. Barboto played the kick right into the keeper's box and hit two other players before it landed on Gebhard's thigh. Gebhard wasted no time kicking it into the back of the net.
A: Douidar connects in OT for Tampa Prep
TAMPA — With every errant touch, each mistimed pass and countless wasted opportunities, the frustration mounted for Tampa Prep in its Class A state semifinal against Orangewood Christian.
The Terrapins looked comfortable in the first half, shaky in the second and despondent after the Rams equalized with 20 minutes remaining.
In one moment of overtime brilliance, however, that dissatisfaction disappeared.
In the third minute (83rd overall) of extra time, Tampa Prep junior Michael Spezza sent a long pass ahead to Shaddy Douidar that bounced off the head of a Rams defender and right into Douidar's path. With the ball inside the box and nearing the goal line, Douidar, seemingly out of room, found a sliver of space between Orangewood goalkeeper Ben Overbeek and the near post and squeezed a left-footed shot through it for the winning goal in Tampa Prep's 2-1 overtime victory.
"I thought about taking it with my right, but he gave me my left and I just took a chance," Douidar said. "He was expecting me to go far post. He gave me the front post and I took it. Great ball by Michael."
Tampa Prep (24-1-3), the defending Class A champion, will play for its sixth state title next Friday.
"I didn't think (Douidar) had the angle," Tampa Prep coach Doug Smith said. "When he cut to the outside, I was almost turning away. … I don't know how he put that in, but it was unbelievable."
The first half had the makings of a runaway with Tampa Prep controlling much of the possession. The Terrapins scored first, connecting in the 27th minute when Douidar crossed into the box from the left wing, Thomas Vanegmond one-touched a pass to the back post and Harrison Horton finished past Overbeek.
Orangewood (18-6-1) dug in, keeping more possession in the second half and gaining confidence. The Rams were rewarded in the 60th minute when Jake Stone pounced on a loose ball in front of the net and sent a deflected shot into goal.
"That kind of jolted us a little bit," Smith said.
Orangewood outshot Tampa Prep 6-1 in the second half, but the Terrapins regrouped in overtime to continue on to the state title game, where they have never lost.
Berkeley falls in 2A semis: At Miami, Berkeley Prep's quest for a second consecutive berth in the Class 2A state final ended with a 3-0 loss to Gulliver Prep (19-2-3).
The Buccaneers (16-11-2), who scored 11 goals in three previous playoff contests, watched their offense wilt against a technically sound side that pressured relentlessly.
"We struggled to get any kind of possession and our offense was non-existent," Buccaneers coach Tim Cooper said. "One of the best teams I have seen this year."
Staff writer Joey Knight and correspondent Bryan Burns contributed to this report.

subset: commoncrawl


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Business Law
Ask a Business Lawyer. Get Business Law Questions Answered ASAP.
Welcome! My goal is to do my very best to understand your situation and to provide a full and complete answer for you.
Good morning. If this were me, I would file suit against the contractors to solidify my position against them. Once the suit is filed and ajudgment awarded, you become a judgment creditor and can have the sheriff servea summons on the losing party for a debtor examination. That forces the losingparty to meet the judgment creditor in court and answer questions under oathabout the losing party's assets. After that information is obtained, the judgment creditor has the power to garnish wages, attach bankaccounts, and/or have the sheriff seize other property to satisfy the judgment.
I hope this has given you information that has beenhelpful to you. If the information seems more general than specific, please be aware that we are only allowed toprovide information and not specific advice. If you have a follow-up question, please remember thatthere might be a delay between your follow up questions and my answers becauseI may be helping others or taking a break.
If you do have any additional questions about my answerplease simply ask a follow up question without rating so I can provideyou with a fully satisfactory answer. Please be aware that any rating of 1 or 2 isreflected as a negative rating, reflects negatively on my performance, and Ireceive no credit for my answers.
Thanks for allowing me to be of service to you. Please beaware that the information provided here is not legal advice. Rather it issimply general information. All states have intricacies in their laws and anyinformation given is simply information only and specifically is notintended to be, nor does it constitute, legaladvice. This communication does not establish an attorney-client relationshipwith you. I hope this answer has been helpful to you.
Thanks for that
I just have a few follow ups
How do I file suit
Find a good attorney
How much will it cost
Will I have to go to court or can my attorney take my place
How long can I expect this will take
You're welcome. I have addressed each of your questions below in bold, underlined, italicized text....
How do I file suit...Because the amounts are in excess of the small claim court limits, you will need to file these in state district court. Although you could do this on your own, you would be well advised to have an attorney file the complaints for you.
Find a good attorney Either the Massachusetts State Bar Association or your nearest law school would be excellent sources of referrals. I would recommend the latter for a recent graduate. These are not complicated cases and thus you don't need a really experienced lawyer who will carry a high billing rate.
How much will it cost You should be able go get these cases filed and handled for a couple thousand dollars.
Will I have to go to court or can my attorney take my place Yes, if the defendants don't pay you before the hearing, you will need to appear at the hearing.
How long can I expect this will take I can't say for sure because it will depend upon the court's docket, but you should be able to get these resolved within a month.


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Products we wish they'd bring back from the dead
The gooey, mousse-filled bar with a 'nest' of milk chocolate was probably deemed to sickly sweet for most consumers, but I certainly managed to 'consume' enough of these in the sixth form common room! There was something ever so light and uplifting about eating one of those bars, and I still get cravings for them! A wallnut whip just doesn't quite hit the spot. Last seen: late 1990s
John Frieda Beach Blonde
John Frieda's Beach Blonde range of haircare products was a popular range with some innovative products for many years until it disappeared around 2005. Many still bemoan the loss of Cool Dip shampoo and Smooth Seas Conditioner, which actually lightened hair as it was used - a bit like a 'posh Sun-In'. There was also a sea salt spray that was the first of its kind.
A quick browse through beauty and shopping forums shows that the products are sorely missed, and there's even a petition to bring them back. If you're really desperate you can buy an opened bottle of Beach Blonde on eBay, but you'd have to save it for special occasions only if you wanted it to last! Last Seen: early 2007 in some stores.
Nik Naks are synonymous with school days for anyone who was a kid in the last 20-odd years, when it seems we couldn't get enough of the chemically-flavoured corn snacks. During the 90s, makers of the snack started to become concerned about how 'smelly' some of their flavours were, and they started to tinker with the original formulas. This resulted in the loss of Scampi & lemon, and later a hard cheese flavour that is now sorely missed. I think they mis-judged their audience there: kids love stuff that stinks!
But all may not be lost if you were a huge fan of the stinky snack: in 2011, a petition resulted in the return of Nik Naks' Scampi & lemon flavour, which had been discontinued in 2008.Last smelled: some time in the early 2000s.
Flipz White fudge pretzels
Apparently, the UK market hasn't quite got a taste for the salty-sweet combination of chocolate pretzels yet, so they took away one of the best brands that offered several different flavours: Flipz! Pretzel Flipz were a US import we loved, but sadly not enough to make it worth their while sticking around.
If you've got a real taste for the choccy-covered snacks you can still buy Flipz at Cyber Candy and other specialist sweet shops, but at a much higher cost than they originally fetched in supermarkets. Availability is also limited. Try M&S for a chocolate coated pretzel you can bag in your lunch hour. Last Seen: circa 2008.
...and a few we were glad to see the back of
Google Wave - We all had membership, but we're still not sure what it did
Tab clear - Coca cola but the wrong colour. Pointless!
Which products do you wish they'd bring back from the dead?


text: If you are busted in an undercover drug sting, chances are that you are probably not trying to score some pot. Scott Evans, an actor who used to be on One Life To Live and younger brother of Captain America, Chris Evans was arrested for attempting to possess a controlled substance which is a felony. The actor didn't even seem to care that he is facing felony drug charges as he wrote on his Facebook yesterday that he can't believe it took him a year of being in LA before he was arrested. That is classy.


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Why Syria matters
WASHINGTON (AP) -- The issue:
Syria's conflict is the most violent to emerge from last year's Arab Spring. The protests started peacefully but prompted a brutal crackdown by President Bashar Assad's government. The fighting has escalated into a civil war that has killed at least 23,000 people over the last year-and-half, according to activists. Despite intervening in Libya, the United States has steered clear of taking military action or arming Syria's rebels.
Where they stand:
President Barack Obama called for Assad to step down more than a year ago and has sought consensus for a diplomatic power-transfer plan. He has been stymied by Russia and China, which have blocked efforts at the United Nations to end the Assad regime. He has been unable to prevent a worsening civil war between Assad's forces and the rebels, but remains opposed to enforcing a no-fly zone over Syria or providing the opposition with weapons. His administration says such plans would further militarize Syria. Instead, it hopes better coordination among the opposition will help it unite the country against Assad.
Romney has demanded "more assertive" tactics to end the Assad regime, blaming Obama for a "lack of leadership." The Republican challenger has been vague on specifics. He stresses U.S. cooperation with partners to arm Syria's rebels -- which the Obama administration has been doing in a limited fashion for several months. He has spoken of possibly sending American troops into Syria if weapons of mass destruction are loose -- going slightly further than Obama, who calls WMD his "red line" in the conflict. And Romney wants more U.S. pressure on Moscow to break the diplomatic logjam.
Why it matters:
The future of the Arab world's democracy efforts could hinge on Syria. After demonstrators ended dictatorships out in Tunisia and Egypt, a U.S.-led mission helped defeat Moammar Gadhafi in Libya and a transition deal brought change to Yemen, the four-decade Assad regime has dug in to hold on to power. It is accused of torture and mass killings. And if it succeeds, reform-wary leaders across the region could take it as a lesson that they can attack their own citizens and get away with it.
Syria's close alliance with Iran is important. The Assad regime has facilitated Iran's assistance to militant groups Hamas and Hezbollah, destabilizing Lebanon while threatening Israel's security and American interests in the Middle East. The U.S. accuses Iran of managing Syria's repression to prop up its faltering ally. With Washington and Tehran battling for influence in the Arab world, the change toward a more U.S.-friendly government in Syria would be a major strategic victory. Up to now, the only governments ousted in the Arab Spring were either U.S. allies or counterterrorism partners.
For Obama, Assad's perseverance also poses a credibility problem. The president has demanded that Assad leave power, but has ruled out several elements of American power to make that happen. He has limited the repercussions on Assad mainly to tighter U.S. sanctions and harsher rhetoric. For Romney, however, Syria offers up no easy solution. The presence of al-Qaida-linked fighters and other extremists in the opposition makes members of both parties uneasy about offering greater U.S. aid. And no one wants greater instability on Israel's up-to-now secure northeastern border.
Posted | Updated


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Lindsay Lohan Strips Down in 'Let The Games Begin' (VIDEO)
Lindsay Lohan's latest project, art seems to be imitating life. The troubled actress stars as herself in a new music video for Florida based rockers The Miggs. As the video opens, Lindsay is glamming up for photo shoots, running away from the paparazzi and leaving a club late at night — all while the conscious citizens of L.A. are up in arms about an anonymous graffiti artist.In
How are the two plots connected? Spoiler alert!
LiLo is the one behind the Bansky-esque art! If we haven't lost you yet, it's worth it to stick through the spray paint montage, where Lindsay and a gal pal do a fast strip down in an alley. Watch the "Let The Games Begin" music video above and sound off in the comments.
Lindsay has been laying low for the most part following her house arrest, but did make time to pose for some racy photos with celebrity photographer Tyler Shields. The pics, which were unveiled earlier this week, show Lohan in some seriously scandalous poses, covered in blood and holding a knife and gun in some shots.


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Week Three: Buchtel (1-1) @ St. Vincent-St. Mary (1-1)
7 p.m. Friday at John Cistone Field
Storyline: Buchtel coach Ricky Powers certainly isn't scheduling powder puffs this season. The Griffins want to win against quality opponents.
It worked out in a week one, 29-13 stunner at Massillon. Week two against Pittsburgh Central Catholic? Not so much in a 35-6 loss to the storied Pittsburgh program.
How will they fare against neighboring rival St. Vincent-St. Mary?
The Griffins are loaded with freakish athleticism. Quarterback Tyler Jones is a speedy haul in the running game and playmakers are all over the place on both sides of the ball.
But, in order to be successful they will have to minimize their mistakes. Although they were able to beat Massillon, the Griffins still threw three interceptions and lost a fumble. Massillon turned it over seven times. Last week, Buchtel threw at least two interceptions and had two punts blocked.
It's hard to figure out what to make out of St. Vincent-St. Mary so far this season. They rolled over struggling Akron North 48-0, who is dealing with a lot of issues this season.
And St. V-M lost 20-7 to a strong Columbus Bishop Watterson program in week one. In the loss they turned the ball over seven times.
Senior Doran Grant rushed for three touchdowns and 59 yards last week and caught a touchdown pass in week one.
Whoever can minimize the mistakes Friday should be able to take their record to 2-1.
[poll id="18"]
Can't make the game Friday? No worries. You can follow us on Twitter at https://twitter.com/ABJ_Varsity for up-to-date scoring throughout the contest and scores from around the area as we get them.


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Systemic Thinking
Systemic Thinking is a process of understanding and transforming complex situations - these may include water catchments, a client's market, manufacturing and external environment, projects etc. Systems thinking works through enabling all stakeholders to see their role, their responsibilities and the organisation's strategic imperatives as interdependent.
Purpose: A system can only be conceived when there is a clear articulation of an organisational purpose. That is some relationship has to be articulated that allows the issue to be discriminated from the environment. The purpose usually expresses the dimensions of the relationship between the system and its environment.
Boundaries: As soon as a purpose has been expressed the boundaries of the system can be identified. In this process the aspects of the environment that are encompassed in the system are articulated. The process of boundary identification also shows what parts of the environment are marginal to the system. That is just included or just excluded. Boundary judgements are an important characteristic of Systemic Thinking.
Coherence: All the dynamics that exist within a system need to have a coherence (a sense of wholeness) if they are to be a legitimate part of that system. A test for coherence is often conducted to assist boundary judgements.
Emergence: A characteristic of systems is that the whole has characteristics that can not be identified from a study of the systems parts. The characteristics that arise from wholeness are termed emergent characteristics. Searching for emergent characteristics in complex systems is an important area of Systemic Thinking.
Hierarchy: Every issue that is looked at systemically can be understood as having three levels of activity, that is a three level hierarchy—supra-system, system and sub-system. The ability to hold these three levels of hierarchy in your mind at the same time while considering an issue and appreciating the way in which changes at one level affect changes at the other levels is known as systemic thinking.
Sub-systems: These are the parts of the system that have to interact in an interdependent way for the system to achieve a balance and express its purpose on the supra-system. The parts are also the only way a system can learn about its environment, they are the power-house that give life to the system.
Environment: This is a term often given to the supra-system and encompasses all things not included in the system by its purpose. Obviously there will be some aspects of the environment, which have a close relationship with the system while other dimensions will seem to be totally unrelated. However, in Systemic Thinking all aspects have some relationship to the system although it may be very tenuous and the pathway of the relationship almost impossible to discover.
The key idea here is that systems are whole entities with properties that are different from those of the sums of their (interconnected) parts.


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POCATELLO, IDAHO -- I went to the Pocatello Idaho store at 800 Yellowstone Ave and was as overcharged on an item. I went to customer service and the older female was rude and not helpful. I then asked to just refund me and she was even ruder. Don't shop at this Fred Meyer until they get their act together. Almost every time I go I get overcharged on something. They don't like being caught at it. They have serious employee and management problems. Old, at the last sale date food too. Stay away.
BEAVERTON, OREGON -- I walked into Freddie's and came upon the health food aisle, looking for peanut clusters. A woman by the name of Kim ** was there and I asked her for assistance, she immediately had an attitude. I asked her if there is anywhere else I can find these, she said, "well where all the other candy is - right on aisle 5." I went up and down that aisle, nothing! So I went back to her and asked her to help me out, since I could not see anything there. She also went up and down - nothing! She then looked at me and said "this is not my aisle, I do not work this aisle."
I then asked why in the world she would even send me there, that just sent her into a hissy, and she then turned and walked away from me. I then muttered "wow that was lazy." She turned around and asked what I said. I told her, she then threaten to call security. Why? Because she did not like what I said. I reported this to the manager Scott. He could have cared less. Upon walking out, they both laughed their heads off! That is how Fred Meyer treats their customers? Really?
Fred Meyers informed me that their employees are always right and never need to apologize to anyone. We'll wait 'til I post all of this on social media and contact everyone I can think of! Absolutely unacceptable! Or was it just that I happen to be black?
CLACKAMAS, OREGON -- My daughter and I were shopping at the 82nd drive Freddies about a year ago, and a wonderful employee (his name was **) helped us track down a certain craft for my daughter's science project. He must have spent thirty minutes calling stores all while helping countless other customers with ease and grace! Once he helped us with the product, my daughter said "you are very good at your job" to which he replied "it's what I'm born for." Recently I visited again asking of him, and management said he was terminated for being too customer conscious and being awesome. Why did this happen to the Lord's gift to customers? Will only shop at Wal-Mart now!
FLORENCE, OREGON -- We had just gotten paid two weeks ago and bought some clothes, along with some groceries. We are daily shoppers at the local Fred Meyers and are constantly using our rewards card. We had bought 3 pairs of pyjamas, for me and my kids. All 3 pairs did not fit so we went in and tried to return them. The lady behind the counter was very rude to us. She wouldn't allow us to return the clothes because we had washed them, even though we don't go home and just put on clothes, we wash them first. She then went on to tell us there were stains on the clothes even though there was nothing on the clothing.
She then proclaimed that it was our fault for choosing the wrong size and it was our responsibility to check what the clothes were made of. Even though the sizing was wrong she said it was our fault. I wouldn't leave until I got MY money back for faulty clothing. The lady only returned 3 items out of 6 and said the other 3 were not on our rewards card. WE WILL NEVER SHOP AT THIS FRED MEYERS FOR CLOTHES EVER AGAIN. They were very rude, and made this whole experience very bad for us, especially the fact the women blamed us for their faulty products.
KENT, WASHINGTON -- After work I visited my local Fred Meyer (a store I shop at several times a week) to pick up a couple of grocery items, hair care products, a few items of clothing, etc.
I chose to stand in (the often very long) line rather than use the u-scan as the female that is usually there manning them never fails to be rude to me. When using them in the past; I once accidentally stepped in her path, I move out of her way and apologize with a smile only to be referred to as a ** under her breath. Another time, I had the audacity to use the cash-back feature on the pin pad. When I approached her with my receipt to obtain MY cash, she rudely told me that she was not a bank and suggested the next time I "ask her first before assuming I can withdrawal money"!
On this day, I stood in line, then when I got to the belt, I unloaded my items then started flipping through a magazine while awaiting my turn. Unfortunately, she was promoted to cashier but since my items were already unloaded I decided to stay in that line. She was ringing up a young family and there were 3 teenaged boys were in front of me when I heard "Hey". I didn't look up as I didn't think anyone was referring to me. I heard it again and one of the boys tapped me to tell me she wanted my attention. I looked up and she handed me the closed sign, with a curt "put this over there" (there was another man behind me). I did as I was instructed then went back to the magazine.
As she rang up the young men, I heard "Is this on WIC?" Again, I didn't look up as I assumed she was talking to someone else. She repeated herself, this time, louder and sounding more frustrated so I looked up out of curiosity to see who she was taking to so rudely. When I looked up, I noticed the 3 young men and the cashier staring at me, all waiting for me to answer.
I was completely humiliated (before everyone assumes I am snobby please understand, I use the word humiliated because of the disgust in her tone and the manner in which she chose to ask such a question - loudly and in front of several people and it wasn't even my turn to be rang up - one of which anyone would feel the same). I responded, with equal disgust in my tone with a curt "no!" then went back to my magazine. When it was my turn to be rang up, I asked her why she asked that and she responded "all WIC mothers buy the same things". Said things, I assume, was my milk and Apple Jacks (the only food items I had among a bill that totalled $286).
I've let this female ruin my day many times simply because I didn't want to put forth the effort to complain but I feel I need to finally say something. Unfortunately, the location of this store is very convenient but I will definitely make sure to never have to deal with her again!
PORTLAND, OREGON -- I have been shopping at this location for almost 15 years. I have always been loyal to this store and only go to others when I absolutely have to. Now, I hate to complain about people at stores, but Lordy, this store stinks now. The current assistant food manager (a large troll looking man) is the rudest person I have EVER dealt with.
Two weeks ago I was shopping there and was looking for some vitamins in the natural food section. It was later in the day, and no one was working there. I waited for a few seconds until I saw someone pass by. I asked them if they knew anything about the product, they did not, so they paged customer service.
Almost instantly a charming young man walked up and asked how he could assist me. There was a short girl with him, who seemed to be new because she was listening to his every word. Both of them assisted me finding the products I needed, and when they didn't have a product in their department they took me to another section of the store and showed me where they were.
As I was leaving the store, I saw them straightening up a cooler near the self check out. As I got closer someone in management (I later learned it was the assistant food manager) walked up to them and told them to stop working together, go fill the milk, and start working. The girl walked away quickly but the young man stayed and continued to clean. Even though they had just given me excellent customer service, he treated them both like nothing at all.
This was not the only time I have seen this man be rude to employees. Last week this same man was telling another young man to "work faster" and when he was done "redo all the areas he didn't do properly." He then went on about how the food department looked like crap and none of the closers from the previous night did anything right and that he was going to have to take time out of his day to fix it.
He walked away and the young man he was talking to started to complain to another young man in the aisle about how the manager always treated him terribly and he couldn't wait to go back to school so he didn't have to deal with the (and I quote him) "Douchebag manager."
I have never felt like never shopping at a store this much. I love Fred Meyers, but hate the way the lower level employees get treated. All the cashiers have fake smiles on, and anyone in the food department look miserable whenever I shop. Something has to be done. Bring in new management so I can have my old Raleigh Hills back!
SEATTLE, WASHINGTON -- I work for King county I assist a disabled, deaf amputee. He has very little support and few funds. I've been shopping for him for the last five years. I receive a check from King County and I take care of the gentleman's shopping. He also receives some state funds on a debit card. The debit card has been read as zero funds that last three times I've used it. After running it again it has shown sufficient funds. I explained this to the employee who called a manager over and both said it had no funds - which I explained was not possible as last week when the same thing occurred it was run again and had 58 dollars on it and less than 8 was used.
Every time I shop I am looked at with suspicion and the manager is called over to look over the check and ask for ID. I've learned to tell them it's a slash five and they look at me like it's their first day. Tonight I was told the card had one dollar on it and the check could not be accepted as the check was written to client before crossed off (initialed and filled out to Fred Meyer) So the client - did I mention he's deaf and is missing a leg and is mentally handicapped? Yeah that guy he's got no food this week.
Every week I go through this song and dance and holding up the line -but this week perhaps because it was near closing time they chose to let the food in the cart rot rather than go to the trouble to work through their incompetence. Can you not develop a better system to manage a dynamic that's been occurring consistently for the last five years?
I had a very unpleasant experience this evening shopping at Fred Meyers. Many items were on sale, and my husband and I picked up extra quantities to take advantage of the reduced prices. At the cash register, we unloaded our groceries and other items on the belt. The cashier began to ring up our purchases. A friend saw me and walked over to talk for a moment. My husband paid for the items with his credit card. As my friend left, I heard the cashier saying, "Oh, I feel like such a dolt. I forgot to scan your coupons. You'll have to take them over to customer service."
I had planned our shopping trip for the time between work and the start of a favorite TV show. Instead of going home after shopping, however, we stood in line at customer service for 15 minutes. When it was finally our turn, it took another 15 minutes for the full process of crediting us for the $4.67 we'd been overcharged. When we got done with all of that, and we were walking out of the store, I looked over the receipt at the remaining charges. It has been my experience, unfortunately, that sale items are frequently rung up at the full price at Fred Meyers. I usually try to carefully watch the prices being rung up as the cashier does his or her job.
I hadn't watched this time, and sure enough, the 4 skeins of yarn I had purchased for about $23.00 had not been charged at the 20% off advertised in large signs in the craft department. We'd still been ripped off for at least $4.60 even though we'd spent an extra half hour getting reimbursed for coupons that hadn't been scanned.
Several years ago I boycotted Fred Meyers for six months because this kind of experience is not at all unusual. It has been my observation that when I buy a lot of items, and some of them are supposed to be on sale, at least one or two items will always be charged at the non-sale price. This is not the cashier's fault. I object to being overcharged, and I object to having to watch like a hawk to make sure it doesn't happen. I resent even more the embarrassment of having to ask the cashiers, overworked and underpaid though they are, to correct the errors when I catch them before the final total is rung. Fred Meyers, as a national chain, really needs to do better.
LONGVIEW, WASHINGTON -- I shop at the Longview, WA Fred Meyers store regularly and spend over $600-800 a month a least. On one shopping trip I purchased over $150 dollars worth of clothing etc... I tried to return a purse, wallet, and a pair of flip flops but for some reason the items were not showing up under my rewards card. I'm assuming I must have forgotten to input my number during self check-out which is pretty common and not unheard of. I was unable to find my receipt which really irritated me but was OK with accepting store credit since all the items I had purchased were on sale so I did not mind taking the 90 day lowest price.
The older lady with blonde hair told me that she was unable to do the return most likely because the system would not allow me to return anything because I must have exceeded my number of returns. I can only think of one other time I had returned something and it was make-up that was not in my color...
I then politely asked if I could have my mother, relative or friend do the return because I did not want the items to go on clearance and lose out on the money I PAID! She told me she couldn't see why I couldn't and I had my father in law go in to do it. While he was attempting to do the return for me she made snide remarks saying she found it very odd that a man was returning the same items a younger girl came into return just a while earlier when she knew very well that I was planning to send someone in to do it for me. She offended him to the point he had to leave.. I then had my husband go in and she called Loss Prevention.
This is the worst customer service and discrimination I have ever received from any business or retailer. I will never purchase any items from Fred Meyer or Kroger and will gladly take the money right next door to the local Safeway and do my shopping at an actual clothing retailer who doesn't accuse my family members or I of theft just because I had lost a receipt and forgotten to plug my phone number during the check-out process.
Their grumpy customer service associates that have not changed in 10-20 years are not very pleasant people and have a frown from the moment you walk-up to the customer service counter. They use age and racial profiling. I watched an old lady return over $130 worth of merchandise with no questions asked and she did not have a receipt and received a merchandise credit card.
BALLARD, WASHINGTON -- I visit your store a lot and know all your cashiers. I had my husband's credit card and was picking up some cartridges for our printer. The manager said there was no way he was selling me the items because my name wasn't on the card. I asked if he could run as a debit so I could punch in the security pin code and he said no. "No ma'am, there's no way I'm selling you this." Now my husband is disabled and I am in there all the time. 2 cashiers vouched for me saying they knew me and my husband. I would have gotten cash but the card is old and has a crack in it and cash machines that take the whole card in it won't accept it. You can only slide it through a machine.
Anyway he really embarrassed me in front of these two employees who know both my husband and I. Think that if employees are vouching for you and they know you, that THE MANAGER should have taken that into consideration and not been such a jerk. This store used to be so much more neighborly. Whatever happened to knowing your customers and making them feel at home and happy? Seems to me it's become all about money and how many people can you get through your line.
I spend a lot of money in your store but lately I am getting an attitude. Doesn't seem like you know or care to know your customers and your managers do a lot of power tripping in front of customers!!! I always use his card and if they checked my history and my rewards card they would see his name too. But he wouldn't even do that either. If I knew a customer said they came in all the time and other cashiers were vouching for that person I would at least make an effort to check or something. That's why banks have pin #s on cards.


text:
Consumer PR Account Manager & Consumer PR Senior Account Executive
- Recruiter
- Forster Communications
- Location
- London Bridge
- Salary
- SAE c. £26k + benefits, AM c. £34k + benefits
- Posted
- 18 Nov 2013
- Closes
- 30 Nov 2013
- Function
- Account Manager, Senior Account Executive
- Discipline
- Marketing Communications, Press / Media Relations
- Hours
- Full Time
- Contract Type
- Permanent
Ever wondered what it would be like to promote things you really believe in? If you're ready to apply your proven consumer engagement skills into positive social change then we have two fantastic roles waiting for the right people. We're looking for a sparky, creative and commercially minded Account Manager and Senior Account Executive with solid agency pedigrees to join the Forster team.
Forster is the UK's leading social change PR agency, owned, managed and driven by our employees. We build brands with social purpose. Our award winning portfolio ranges from Girlguiding UK and Age UK to the Jamie Oliver Foundation and KPMG.
For the Account Manager, we are looking for:
- At least three years of experience, with the most recent of these working with UK media
- Proven ability to work in a fast-moving agency environment
- Proven experience in running PR campaigns to time and budget
- A nose for news – and creative mindset to generate and respond to it
- Strong proactive and reactive consumer media skills and active journalist contacts
- Delivery of measurable results and client value for money
- Confident written and verbal communications
- Motivating and inspiring management style
For the Senior Account Executive, we are looking for:
- Approximately 18 months – 3 years proven experience in running UK-based PR campaigns
- A nose for news – and creative mindset to generate and respond to it
- Strong media relations skills and active journalist contacts
- Dedication to detail and solid organisational skills
- Confident written and verbal communications
- An active interest in social media
- Commitment to Forster's mission
In return, we can offer:
- A wide range of campaigns, all with the aim of generating real positive social change
- An integrated approach working across channels and in partnership with our Creative team and specialist Network partners
- A unique and inspiring agency environment close to Borough Market, London Bridge
- A generous salary and benefits package, on-going commitment to employee development and wellbeing, and an opportunity to become a company shareholder
If you are interested in applying, please send your CV to email@example.com with a covering letter indicating which role you are applying for and highlighting three examples of recent PR projects you've worked on that make you proud.
Closing date: 27th November 2013
Consumer PR account manager - c. 34k + benefits
Consumer PR senior account executive - c. 26k + benefits
Check us out at www.forster.co.uk
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text:
Entrepreneurship Guest Lecture Series
Start: Jan 17, 2013 05:15 PM
Speaker: Viktoras Jucikas - Founder and CEO of Yplan
Each year, UCL's Department of Management Science and Innovation and UCL Advances organises a series of guest lectures from leading entrepreneurs and investors.
These inspirational speakers provide an insight into the highs and lows of being an entrepreneur and share advice for those wishing to start their own business or who have already embarked on this journey.
Viktoras Jucikas is co-founder and CTO of YPlan, the
world's first mobile-only event booking app that launched in London in
late November, 2012. The app lets you discover top tickets for tonight,
pay in two taps and go to gigs, theatre, cinema, quirky events like
Previously an Executive Director at Goldman Sachs, he left
behind six years of designing exotic derivative risk management tools
and fighting broken dividend curves, to partner up with an old friend
and dive straight into the deep end of mobile commerce and technology
Viktoras graduated from Jacobs University Bremen with an
MSc in Computational Sciences and Kaunas University of Technology with a
BSc in Computer Science. Innovative technology lies at the heart of
YPlan's development, and Viktoras' knowledge and expertise has been
crucial in bringing the product to market. A technical genius with a
keen-eye for detail, Viktoras is an experienced generalist, passionate
and curious about all things mobile, constantly learning and exploring
new mobile UX/UI paradigms, artificial intelligence and machine
Viktoras also leads the Lithuanian City of London Club - providing support and guidance for those wanting to develop interpersonal and networking skills


text:
Simple Spotless Skin Anti-Blemish Moisturiser 75ml
Product Description
Simple skincare contains no animal derived ingredients.
Product Information
Skin Care/
Facial Moisturising/
Day Cream
Teens Toiletries/
Facial Skincare/
Facial Moisturising
Skin Care/
Medicated & Problematic/
Facial Moisturising
- Brands: Simple
For best results:
Smooth gently into your face and neck using upward and outward movements. Use a part of a Spotless Skin regime and try our Rapid Action Spot Zapper for an on-the-go spot solution!
Preparation and Usage
For best results Smooth gently into your face and neck using upward and outward movements. Use a part of a Spotless Skin regime
Country of Origin
Produce of the EU
Unilever Dept ER, Wirral, CH63 3JW, UK.
Package Type
Recycling Information
Packing - Recyclable
Other Information
Full Product Name:
Spotless Skin Anti-Blemish Moisturiser
Made in EU
Aqua, C12-15 Alkyl Benzoate, Propylene Glycol, Glycerin, Glyceryl Stearate, Nylon-12, PEG-100 Stearate, Dimethicone, Zinc PCA, Tapioca Starch, Aloe Barbadensis Leaf Juice, Phytosphingosine, Anthemis Nobilis Flower Oil, Panthenol, Bisabolol, Tocopheryl Acetate, Pantolactone, Lavandula Angustifolia Oil, Cetearyl Alcohol, Dipropylene Glycol, Sodium Hydroxide, Acrylates/C10-30 Alkyl Acrylate Crosspolymer, Benzophenone-4, Methylparaben, Sodium Hydroxymethylglycinate, Potassium Sorbate, Sodium Benzoate
Customer Reviews
05 June 2017
Excellent Product
This is the best spot reducer that I have found. I use the spot reducing face wash, moisturizer and this product in my skin care routine with great results. I now have my teenage daughter doing the same to help prevent breakouts.
12 May 2015
3 of 3 found this review helpful.
Excellent moisturiser for older, spotty skin
Most moisturisers for spot-prone skin just don't moisturise enough; fine if you have oily skin but if, like me, your skin is maturing but you are still getting breakouts, then this is a really good product.
- Tesco Price Match
- ** Matched to Tesco's standard retail price on 24-Jul-2017 at 02:57. See our Terms and Conditions for full details.
- Disclaimer
- These summary details have been prepared for information purposes only, and are designed to enhance your shopping experience on the Ocado website. While we have taken care in preparing this summary and believe it is accurate, it is not a substitute for your reading the product packaging and label prior to use. You should note that products and their ingredients are subject to change. If you do require precise ingredient information you should consult the manufacturer, whose contact details will appear on the packaging or label.
- Ocado is therefore unable to accept liability for any incorrect information. Where this description contains a link to another party's website for further information on the product, please note that Ocado has no control over and no liability for the contents of that website.
- You should also note that the picture images show only our serving suggestions of how to prepare your food - all table accessories and additional items and/or ingredients pictured with the product you are purchasing are not included.
- This data is supplied for personal use only. It may not be reproduced in any way whatsoever without Ocado Limited's prior consent, nor without due acknowledgement.


text:
$~ * IN THE HIGH COURT OF DELHI AT NEW DELHI + INCOME TAX APPEAL NO. 1018/2011 Reserved on: 14th August, 2013 % Date of Decision : 22nd November, 2013 COMMISSIONER OF INCOME TAX ..... Appellant Through Mr. Sanjeev Sabharwal, Sr. Standing Counsel. versus NR PORTFOLIO PVT LTD. ..... Respondent Through Dr. Rakesh Gupta and Mr. Rishabh Kapoor, Advocates. + INCOME TAX APPEAL NO. 1019/2011 COMMISSIONER OF INCOME TAX ..... Appellant Through Mr. Sanjeev Sabharwal, Sr. Standing Counsel. versus NR PORTFOLIO PVT LTD. ..... Respondent Through Dr. Rakesh Gupta and Mr. RishabhKapoor, Advocates. CORAM: HON'BLE MR. JUSTICE SANJIV KHANNA HON'BLE MR. JUSTICE SANJEEV SACHDEVA SANJIV KHANNA, J.
These two appeals by the Revenue relate to a common assessee i.e., N.R. Portfolio Pvt. Ltd. and the questions raised relating to assessment years 2002-03 and 2003-04 are similar. They pertain to the additions made by the Assessing Officer under Section 68 of the Income Tax Act, 1961 (Act, for short) of Rs.1,2,34,100/- and ITA Nos. 1018/2011 & 1019/2011 Page 1 of 24 Rs.75,60,200/- for the assessment years 2002-03 and 2003-04 on account of share application money.
2. The contention of the Revenue is that the Income Tax Appellate Tribunal (tribunal) has dealt with the issue superficially and has failed to notice the money laundering indulged into and the clandestine manner in which unaccounted and black money had been brought into books by this dubious method. It is contended that the decision in the case of CIT Vs. Lovely Exports Ltd. 299 ITR 268 (Del) is being misunderstood and misinterpreted resulting in a spate of matters wherein assessees have adopted this surreptitious method to convert unaccounted for money into share application money.
3. Revenue has relied upon the decision of this Court in the case of CIT vs. Nova Promoters and Finlease (P) Ltd. [2012] 342 ITR 169 (Del).
4. By order dated 13th August, 2013, the following substantial question of law was framed in the two appeals:-
"Whether the Income Tax Appellate Tribunal was right in deleting the additions of Rs.63,80,100/- and Rs.75,60,200/- in respect of Assessment Years 2002-03 and 2003-04 under Section 68 of the Income Tax Act, 1961 and whether the decision of the Tribunal is perverse?"
5. The respondent-assessee is a private limited company and for the assessment years 2002-03 and 2003-04 had filed returns declaring income of Rs.11,566/- and 18,720/-, respectively. These returns were processed under Section 143(1) of the Act. Subsequently, reassessment proceedings were initiated under Section 147/148 of the Act on the basis of information received from the Investigation Wing that the assessee was one of the beneficiaries, who had procured share ITA Nos. 1018/2011 & 1019/2011 Page 2 of 24 application money from entry providers. Assessment proceedings under Section 147/148 of the Act in the two years were initiated by issue of notices on 28th November, 2006. The notices were received back unserved and subsequently were served by affixture at the last known address i.e., the address given in the returns. The assessee, however, did not appear in response to the said notices. The Assessing Officer thereupon on 8th October, 2007 issued show cause notice under Section 144 read with Section 147 of the Act, which was sent through Speed Post, but was returned unserved with the remark "no such firm". Respondent-assessee again was served through affixture on 25th October, 2007. On examining the return for the assessment year 2004- 05, it was noticed that M/s Prakash K. Prakash Chartered Accountants had certified the accounts of the respondent-assessee. Office of M/s Prakash K. Prakash Chartered Accountants was contacted and thereupon they filed their power of attorney on 1st November, 2007. The said Chartered Accountants also filed a letter that the respondent company had not received any notice and had been regularly filing their returns mentioning the correct address and after that there was change in address, the same was informed. Along with this letter, no detail of new address was filed. They had not mentioned the present/current address.
6. Another show cause notice was issued and sent at the last known address of the respondent-assessee and the address of the Chartered Accountants fixing the hearing on 4th December, 2007. The letter referred to the notice under Section 147/148 of the Act, show cause notice under Section 144 dated 8th October, 2007 and the fact that the reasons could be provided only after return of income was filed but yet in the interest of justice and for the purpose of proceedings it was ITA Nos. 1018/2011 & 1019/2011 Page 3 of 24 stated that as per information available, the share capital was received during the years from the persons who had been identified as entry operators. Thus, the respondent-assessee had received accommodation entries which were likely to be hit under Section 68 as unexplained cash credit. Details and manner in which entries were made in the books of account and the clandestine manner of circulation, was stated in detail in the show cause notice.
7. On 4th December, 2007, no one appeared at the time of hearing. Subsequently, a request for adjournment was received by way of courier from M/s Prakash K. Prakash Chartered Accountants and they were allowed time up to 10th December, 2007, but on the said date also, no one appeared and no written request was received. Accordingly, ex-parte or best judgment assessment orders both dated 17th December, 2007 were passed for the two assessment years.We shall be referring to the details/contents of the assessment orders subsequently.
8. The respondent-assessee, however, preferred appeals and substantially succeeded on merits before the Commissioner of Income Tax (Appeals) but did not succeed in their challenge to reopening under Section 147/148 of the Act or on the question of service of notice.
9. Two cross appeals were preferred before the tribunal by the Revenue and the respondent-assessee for the two assessment years but the same have been dismissed by the impugned order dated 29 th October, 2010. The reasoning given by the tribunal is that the respondent-assessee had furnished Permanent Account Number (PAN) of the share applicants except with regard to the share capital of Rs.4,50,000/- and before the Commissioner (Appeals), the assessee ITA Nos. 1018/2011 & 1019/2011 Page 4 of 24 had also submitted various details and documents to establish identity of the investors/share applicants. The impugned order in paragraph 6 refers to and quotes several paragraphs from the order passed by the Commissioner (Appeals) and in paragraph 7 refers to the observations made by the Commissioner (Appeals). Thereafter, in paragraph 8 it is recorded that the tribunal had gone through various reasons and principles on which Commissioner (Appeals) had deleted the addition. Commissioner (Appeals) had given a finding that verification of PAN was made and found to be correct except with regard to the share application money of Rs.4,50,000/- and, therefore, in the light of the judgments of Delhi High Court in CIT v. Lovely Exports Private Ltd.[2008] 299 ITR 268, Winstral Petrochemicals Pvt. Ltd. [2011] 330 ITR 603 and CIT Vs. Dwarkadhish Investment (P) Ltd. [2011] 330 ITR 298 and other cases, addition was not justified and not in accordance with law.
10. Cross objections filed by the assessee were not pressed and in paragraph 20 of the impugned order it is specifically recorded that the validity of notice under Section 148 was not argued by the respondent- assessee and it was fairly accepted that the assessee"s appeals had no merit. The tribunal thereafter held that they had gone through the order of the Commissioner (Appeals) and the findings recorded on the said issue were right. At this stage, we would like to reproduce the findings recorded by the Commissioner (Appeals) on this issue:-
"3.6.2 Similar is the position with regard to service of show- cause notice for completing the impugned assessment u/s 144 of the Act as it is an established fact that in absence of any intimation with regard to change of registered office address from the appellant company, the assessing officer has left with very little option except getting the same served through affixture. It is beyond doubt that the assessing officer took pains to locate the authorized representative M/s Prakash K.ITA Nos. 1018/2011 & 1019/2011 Page 5 of 24
Prakash, CAs and served show- cause notice on them meaning thereby that the appellant was fully in known of the things that the assessment proceedings are going on and it is required to file information with regard to the various points on the basis which the case was reopened u/s 147/148 of the Act. It is matter of record that after the authorized AR could be located by the assessing officer, the AR filed a letter dated "nil" along with POA dated 1-11-2007 but still the appellant chose not to intimate the address to the assessing officer except vaguely stating that the Department have been informed about the change of address from time to time. In these circumstances, I do not see any justification on the part of the appellant to either raise the issue of non- service of notices or improper procedure of substituted service and accordingly, I hold that the impugned assessment is in order.
The contentions of the appellant company that the impugned assessment has been framed without looking into the contentions of the appellant has also not found favour with me as despite knowing fully well that the assessment shall be time barred as on 31-12-2007, the AR chose to sent the details through post which were received by the assessing officer on 18-12-2007 whereas the impugned order us passed on 17-12-2008. Otherwise too, during the present proceedings, the assessing officer submitted a remand report wherein the appellant has not been given an opportunity to put forth its view points and on which rejoinder has also been filed which means that the principle of natural justice has been adhered to and hence contention of the Ld. AR needs rejection."
11. Other findings recorded by the Commissioner (Appeals) refers to the remand report which was called from the Assessing Officer stating that notice under Section 148 was sent at the last known address i.e., F-280, New Rajinder Nagar, New Delhi, which was also mentioned in the return of income, but was received unserved with the remark "no such assessee", but subsequently served through affixture at A-46, Mohan Co-op. Industrial Estate, Mathura Road, New Delhi, the address which was shown in the return of income for the assessment year 2004-05. The Assessing Officer in the remand report ITA Nos. 1018/2011 & 1019/2011 Page 6 of 24 has mentioned that the assessee"s registered office was located at A-46, Mohan Co-op. Industrial Estate, Mathura Road, New Delhi on the date of affixture of notice. Subsequently, on 18th April, 2007, they shifted their registered office to A-15, B-1 Extension, Mohan Co-op. Industrial Estate, Mathura Road, New Delhi. We have already quoted the observation of the Assessing Officer after M/s Prakash K. Prakash Chartered Accountants were served and they in their letter dated 1 st November, 2007 had not furnished the new address, though the respondent-assessee have stated that they had shifted their registered office address from A-46, Mohan Co-op. Industrial Estate, Mathura Road, New Delhi to A-15, B-1 Extension, Mohan Co-op. Industrial Estate, Mathura Road, New Delhi. The respondent-assessee had also stated that they had "misplaced" the intimation filed with the department on change of address. The Commissioner (Appeals) has recorded a finding that the respondent-assessee had wrongly claimed that they had informed the department about change of their registered office address, as not even a single intimation was presented before the Assessing Officer or him.
12. The contention of the Ld. AR for the appellant, that they had intimated change of address to Registrar of Companies, and the Assessing Officer should have ascertained the said address, it was rightly observed could not cut any ice in the facts of the present case. It was the obligation and responsibility of the respondent- assessee to intimate change of address to the Assessing Officer as no return with the new address was furnished or even filed. Further, the conduct of the respondent, when they did not give the latest address in spite of the fact that M/s Prakash K. Prakash, Chartered Accountants were served and informed about the proceedings, speaks for itself. Their conduct in ITA Nos. 1018/2011 & 1019/2011 Page 7 of 24 not responding and appearing before the Assessing Officer was adversely commented upon by the Commissioner (Appeals) and the said finding has not been disturbed by the tribunal. However, this fact and the conduct of the respondent before the Assessing Officer was not noticed and given adequate reference while dealing with the question of deletion of addition on merits.
13. The Assessing Officer is both an investigator and an adjudicator. When a fact is alleged and stated before the Assessing Officer by an assessee, he must and should examine and verify, when in doubt or when the assertion is debatable. Normally a factual assertion made should be accepted by the Assessing Officer unless for justification and reasons the assessing officer feels that he needs/requires a deeper and detailed verification of the facts alleged. The assessee in such circumstances should cooperate and furnish papers, details and particulars. This may entail issue of notices to third parties to furnish and supply information or confirm facts or even attend as witnesses. The Assessing Officer can also refer to incriminating material or evidence available with him and call upon the assessee to file their response. We cannot lay down or state a general or universal procedure or method which should be adopted by the assessing officer when verification of facts is required. The manner and mode of conducting assessment proceedings has to be left to the discretion of the assessing officer, and the same should be just, fair and should not cause any harassment to the assessee or third persons from whom confirmation or verification is required. The verification and investigation should be done with the least amount of intrusion, inconvenience or harassment especially to third parties, who may have entered into transactions with the assessee. The ultimate finding of the assessing officer should ITA Nos. 1018/2011 & 1019/2011 Page 8 of 24 reflect due application of mind on the relevant facts and the decision should take into consideration the entire material, which is germane and which should not be ignored and exclude that which is irrelevant. Certain facts or aspects may be neutral and should be noted. These should not be ignored but they cannot become the bedrock or substratum of the conclusion. The provisions of Evidence Act are not applicable, but the assessing officer being a quasi judicial authority, must take care and caution to ensure that the decision is reasonable and satisfies the canons of equity, fairness and justice. The evidence should be impartially and objectively analyzed to ensure that the adverse findings against the assessee when recorded are adequately and duly supported by material and evidence and can withstand the challenge in appellate proceedings. Principle of preponderance of probabilities applies. What is stated and the said standard, equally apply to the Tribunal and indeed this Court. The reasoning and the grounds given in any decision or pronouncement while dealing with the contentions and issues should reflect application of mind on the relevant aspects.
14. When an assessee does not produce evidence or tries to avoid appearance before the Assessing Officer, it necessarily creates difficulties and prevents ascertainment of true and correct facts as the Assessing officer is denied advantage of the contention or factual assertion by the assessee before him. In case an assessee deliberately and intentionally fails to produce evidence before the Assessing Officer with the desire to prevent inquiry or investigation, an adverse view should be taken. We shall now come to the merits and the findings recorded by the Commissioner (Appeals), which as noted above, have been simply affirmed by the tribunal without verifying or ITA Nos. 1018/2011 & 1019/2011 Page 9 of 24 referring to the facts.
15. In the present case, the undisputed position is that the respondent had received share application money of Rs.68,30,100/- and Rs.75,60,200/- in the Assessment Years 2002-03 and 2003-04 respectively. For the Assessment Year 2002-03, the Assessing Officer had taken the share application money received in the year as Rs.1,20,34,100/-, which included Rs.32,80,000/- and Rs.19,24,000/- related to previous years or was the opening share capital. As noted above, addition of Rs.4,50,000/- has been sustained in the Assessment Year 2002-03. Thus, the Commissioner (Appeals) and the tribunal have deleted additions of Rs.63,80,100/- and Rs.75,60,200/- in the two assessment years. Before the Commissioner (Appeals), the respondent-assessee had furnished name of the share applicants which mostly consisted of companies. It was accordingly submitted that the respondent had been able to establish identity of the shareholders, their creditworthiness and also genuineness of the transaction as the payments were received through banking channels. Thus, the respondent had discharged the primary onus and there was no evidence or material to show that unaccounted for money was recycled and introduced in the books as share application money. The Commissioner (Appeals) has recorded that verification of PAN numbers was done in the present case and was found to be correct except in the case of Technochem Associates Private Limited and M/s Yogesh Gupta from whom share application money of Rs.1,50,000/- each was raised but no PAN details were furnished. Regarding Ganga Infin Private Limited, PAN number furnished was found to be incorrect and accordingly addition of Rs.1,50,000/- was justified. With regard to others, the Commissioner (Appeals) has recorded that the assessing officer had not affected inquiries to bring on record and ITA Nos. 1018/2011 & 1019/2011 Page 10 of 24 establish that the other parties had given accommodation entries and the money, i.e., the share application money was assessee"s own undisclosed income. It was further recorded that the respondent had not been provided an opportunity to cross-examine the so-called entry providers and the assessing officer simply relied upon the investigation reports/information provided by the Information Wing of the Department.
16. The aforesaid finding of the Commissioner (Appeals), which have been affirmed by the tribunal, ignores the finding of the Assessing Officer that the Assessee had failed to attend the assessment proceedings,explain and put forward their stand and stance. To this extent, there is contradiction in the order passed by the Commissioner (Appeals), which was ignored and not taken note of by the tribunal.
17. The Commissioner (Appeals) thereafter proceeded on the basis that even if the subscribers to the share capital were not genuine, the amount received cannot be regarded as undisclosed income of the respondent-assessee. Reference was made to the decision of the Delhi High Court in Lovely Exports Private Limited and Divine Leasing and Finance Limited (supra). Reference was made to some decision of the tribunal. It would be here relevant to highlight and note what was recorded by the Assessing Officer in the assessment order. The Assessing Officer has mentioned that the subscribers belonged to Mahesh Garg group of entry operators, which included 51 companies/ persons, who were operating more than 100 bank accounts in different banks/branches. Their modus operandi was to provide accommodation entries to different persons/beneficiaries. Reference was made to the bank statements of the entry operators that showed substantial deposit of cash in the bank accounts and subsequent issue of cheques to the ITA Nos. 1018/2011 & 1019/2011 Page 11 of 24 beneficiaries. This was the only activity of these companies/persons. The said companies/persons were not carrying on any other business activity i.e., manufacturing or trading activity. The assessment order has quoted and referred to the bank account statements in support of the said assertion and finding. The Assessing Officer has mentioned that the respondent-assessee was a private limited company, closely held and there should be proximate relationship between the promoter directors and the shareholders. Closely held companies usually receive share capital subscriptions from friends, relatives and not from unrelated/ unknown third parties/ general public. There was no relationship or connection between the subscribers and the respondent- assessee, for subscribers to become investors. Assessment order records that to establish identity and availability of funds, it was necessary to have at least some idea if not complete details of the actual business undertaken and engaged in by the respondent-assessee and explained how and why these unrelated and unconnected third parties decided to become investors in the absence of public issue or advertisement.
18. In the remand report, the Assessing Officer referred to the provisions of Section 68 of the Act and their applicability. The word "identity" as defined, it was observed meant the condition or fact of a person or thing being that specified unique person or thing. The identification of the person would include the place of work, the staff, the fact that it was actually carrying on business and recognition of the said company in the eyes of public. Merely producing PAN number or assessment particulars did not establish the identity of the person. The actual and true identity of the person or a company was the business undertaken by them. This according to us is the correct and true legal ITA Nos. 1018/2011 & 1019/2011 Page 12 of 24 position, as identity, creditworthiness and genuineness have to be established. PAN numbers are allotted on the basis of applications without actual de facto verification of the identity or ascertaining active nature of business activity. PAN is a number which is allotted and helps the Revenue keep track of the transactions. PAN number is relevant but cannot be blindly and without considering surrounding circumstances treated as sufficient to discharge the onus, even when payment is through bank account.
19. On the question of creditworthiness and genuineness, it was highlighted that the money no doubt was received through banking channels, but did not reflect actual genuine business activity. The share subscribers did not have their own profit making apparatus and were not involved in business activity. They merely rotated money, which was coming through the bank accounts, which means deposits by way of cash and issue of cheques. The bank accounts, therefore, did not reflect their creditworthiness or even genuineness of the transaction. The beneficiaries, including the respondent-assessee, did not give any share-dividend or interest to the said entry operators/subscribers. The profit motive normal in case of investment, was entirely absent. In the present case, no profit or dividend was declared on the shares. Any person, who would invest money or give loan would certainly seek return or income as consideration. These facts are not adverted to and as noticed below are true and correct. They are undoubtedly relevant and material facts for ascertaining creditworthiness and genuineness of the transactions.
20. Vicky Chaurasia, additional director of the respondent company was asked to appear before the Assessing Officer pursuant to the letter by the Commissioner (Appeals) directing the Assessing Officer to go ITA Nos. 1018/2011 & 1019/2011 Page 13 of 24 through the submissions and submit a report after carrying out necessary inquiries. He was asked to produce books of accounts and evidence in support. By letter dated 12th October, 2009, the respondent-assessee was asked to furnish details/information. These included details of dividend paid to the shareholders and to show and establish creditworthiness of the parties. Statement of Vicky Chaurasia recorded under Section 131 of the Act dated 5th November, 2009 has been placed on record by the respondent in ITA No. 1019/2011. He has stated that he along with Sandeep Chaurasia had been directors of the company since June, 2003 and the company was engaged in investment and finance, but he could not give details of the subscribed share capital of Rs.2 crores as it was stated that this was before he became the director. He could not also give details of how share capital got subscribed in a private limited company. Specific question was put to him regarding verification of the shareholders as the summons issued to them had by and large remained uncomplied for want of correct addresses. In response, he had stated that the company had supplied addresses of shareholders as per share application forms and in the absence of dividend or any form of return on the investment, the company was not in a position to call the subscribers for cross- examination. The company had not received any letter for change of address etc. Vicky Chaurasia stated that according to him the subscribers, who were allotted shares, continued and had not ceased to be shareholders. With regard to the past directors, he had stated that they had resigned and he was not in a position to produce the same. In the remand report, it was specifically mentioned that books of accounts were neither produced on 5th November, 2009 nor during the course of remand proceedings.ITA Nos. 1018/2011 & 1019/2011 Page 14 of 24
21. The Assessing Officer had issued notices by speed post to 31 parties as per addresses given by the respondent-assessee requiring them to appear for personal deposition, produce books of accounts with complete vouchers and bills and statement of bank accounts for the relevant period. In respect of 22 parties, the notice summons were received back with postal remarks "No such firm/company/person" or a few "Left without address" and a very few "Refused to accept". Remaining 9 parties neither attended and filed any application for adjournments nor filed details. Thus, it was observed that the identities had been only proved on paper, i.e., in form of neutral documents like PAN number, ITR, Registrar of Companies registration, but without full details as to the actual business activities undertaken by these companies, the reason why these companies had made investment in a private limited company etc. This coupled with the fact that there was cash deposits in their bank accounts and withdrawals were highlighted.
22. In the rejoinder filed to the remand report, it was stated that the share applicants were required to appear in person on 17 th November, 2008 in response to summons under Section 131 dated 23 rd October, 2009. Subsequently, fresh summons dated 30th October, 2009 were issued requiring compliance by 7th November, 2009, but the Assessing Officer had sent the remand report on 6th November, 2009 without waiting for compliance of summons. The said submission is without merit as we notice that the order of the Commissioner (Appeals) is dated 1st October, 2010, i.e., much after the date 17th November, 2009 and 7th November, 2009. A wrong year was mentioned in the earlier summons dated 23rd October, 2009. It was only a typographical error and a response or reply from the shareholder would have been sufficient. Further, in the case of 22 parties, the summons were ITA Nos. 1018/2011 & 1019/2011 Page 15 of 24 received back undelivered/unserved.
23. The contention that the Revenue must have evidence to show circulation of money from the assessee to the third party is fallacious and has been repeatedly rejected, even when Section 68 of the Act was not in the statute. In A. Govindarajulu Mudaliar v. CIT [1958] 34 ITR 807, Supreme Court observed that it was not the duty of the Revenue to adduce evidence to show from what source, income was derived and why it should be treated as concealed income. The assessee must prove satisfactorily the source and nature of cash received during the accounting year. Similarly observations were made in CIT vs. M. Ganapathi Mudaliar [1964] 53 ITR 623 (SC), inter alia holding that it was not necessary for the Revenue to locate the exact source. This principle was reiterated in CIT vs. Devi Prasad Vishwanath Prasad [1969] 72 ITR 194 (SC), wherein the contention that the Assessing Officer should indicate the source of income before it was taxable, was described as an incorrect legal position. Thus when there is an unexplained cash credit, it is open to the Assessing Officer to hold that it was income of the assessee and no further burden lies on him to show the source. In Yadu Hari Dalmia vs. CIT [1980] 126 ITR 48, a Division Bench of Delhi High Court has observed:-
"It is well known that the whole catena of sections starting from s. 68 have been introduced into the taxing enactments step by step in order to plug loopholes and in order to place certain situations beyond doubt even though there were judicial decisions covering some of the aspects. For example, even long prior to the introduction of s. 68 in the statute book, courts had held that where any amounts were found credited in the books of the assessee in the previous year and the assessee offered no explanation about the nature and source thereof or the explanation offered was, in the opinion of the ITO, not satisfactory, the sums so credited could be charged to income-tax as income of the assessee of a relevant previous year. Section 68 was inserted in the I.T. Act, ITA Nos. 1018/2011 & 1019/2011 Page 16 of 24 1961, only to provide statutory recognition to a principle which had been clearly adumbrated in judicial decisions."
24. We are conscious of the doctrine of "source of source" or "origin of origin" and also possible difficulty which an assessee may be faced with when asked to establish unimpeachable creditworthiness of the share subscribers. But this aspect has to be decided on factual matrix of each case and strict or stringent test may not be applied to arms length angel investors or normal public issues. Doctrine of "source of source" or "origin of origin" cannot be applied universally, without reference to the factual matrix and facts of each case. The said test in case of normal business transactions may be light and not vigorous. The said doctrine is applied when there is evidence to show that assessee may not be aware, could not have knowledge or was unconcerned as to the source of money paid or belonging to the third party. This may be due to the nature and character of the commercial/business transaction relationship between the parties, statutory postulates etc. However, when there is surrounding evidence and material manifesting and revealing involvement of the assessee in the "transaction" and that it was not entirely an arm"s length transaction, resort or reliance to the said doctrine may be counter- productive and contrary to equity and justice. The doctrine is not an eldritch or a camouflage to circulate ill gotten and unrecorded money. Without being oblivious to the constraints of the assessee, an objective and fair approach/determination is required. Thus, no assessee should be harassed and harried but any dishonest façade and smokescreens which masquerade as pretence should be exposed and not accepted.
25. In Lovely Exports (supra), a Division Bench examined two earlier decisions of this court in CIT vs. Steller Investment Ltd. [1991] 192 ITA Nos. 1018/2011 & 1019/2011 Page 17 of 24 ITR 287 (Delhi) and CIT vs. Sophia finance Ltd. [1994] 205 ITR 98 (FB) (Delhi). The decision in Steller Investment's case (supra) was affirmed by the Supreme court but, by observing that the conclusion was on the facts and no interference was called for. Lovely Exports (supra) was a case of public limited company where shares were subscribed by public and it was accordingly observed:-
"This reasoning must apply a fortiori to large scale subscriptions to the shares of a public Company where the latter may have no material other than the application forms and bank transaction details to give some indication of the identity of these subscribers. It may not apply in circumstances where the shares are allotted directly by the Company/assessee or to creditors of the assessee. This is why this court has adopted a very strict approach to the burden being laid almost entirely on an assessee which receives a gift."
26. Thereafter reference was made to Full Bench decision in the case of Sophia Finance Ltd.'s case (supra) wherein it has been observed that if the shareholders exists then, "possibly", no further enquiry needs to be made and that the Full Bench had not reflected upon the question of whether the burden of proof rested entirely on the assessee and at which point this burden justifiably shifted to the assessing officer. The Full Bench has observed that they were not deciding as to on whom and to what extent was the onus to show that the amount credited in the books of accounts was share capital and when the onus was discharged, was not decided. The standard of proof might be rigorous and stringent and was dependent upon nature of the transaction and where there was evidence that the source of investment cannot be manipulated, it was material. Similarly, it was observed that assessee could scarcely be heard to say that he did not know the particulars of a donor in case of a gift. It was held:-ITA Nos. 1018/2011 & 1019/2011 Page 18 of 24
"There cannot be two opinions on the aspect that the pernicious practice of conversion of unaccounted money through the masquerade or channel of investment in the share capital of a company must be firmly excoriated by the Revenue. Equally, where the preponderance of evidence indicates absence of culpability and complexity of the assessee it should not be harassed by the Revenues"s insistence that it should prove the negative. In the case of a public issue, the Company concerned cannot be expected to know every detail pertaining to the identity as well as financial worth of each of its subscribers. The Company must, however, maintain and make available to the Assessing Officer for his perusal, all the information contained in the statutory share application documents. In the case of private placement the legal regime would not be the same. A delicate balance must be maintained while walking the tightrope of Section 68 and 69 of the Income Tax Act. The burden of proof can seldom be discharged to the hilt by the assessee; if the AO harbours doubts of the legitimacy of any subscription he is empowered, nay duty-bound, to carry out thorough investigations. But if the Assessing Officer fails to unearth any wrong or illegal dealings, he cannot obdurately adhere to his suspicions and treat the subscribed capital as the undisclosed income of the Company.....................
xxxx ..........Once material to prove these ingredients are produced it is for the Assessing Officer to find out as to whether, on these materials, the assessed has succeeded in establishing the ingredients mentioned above. The Assessing Officer `lift the veil" and enquire into the real nature of the transaction. C.I.T. v. Ruby Traders and Exporters Ltd. : [2003]263ITR300(Cal) , C.I.T. v. Nivedan Vanijya Niyojan Ltd. [2003]263ITR623(Cal) and C.I.T. v. Kundan Investment Ltd.
[2003]263ITR626(Cal.) are the other three.
In this analysis, a distillation of the precedents yields the following propositions of law in the context of Section 68 of the IT Act. The assessee has to prima facie prove (1) the identity of the creditor/subscriber; (2) the genuineness of the transaction, namely, whether it has been transmitted through banking or other indisputable channels; (3) the creditworthiness or financial strength of the creditor/subscriber. (4) If relevant details of the address or PAN identity of the creditor/subscriber are furnished to the Department along with copies of the ITA Nos. 1018/2011 & 1019/2011 Page 19 of 24 Shareholders Register, Share Application Forms, Share Transfer Register etc., it would constitute acceptable proof or acceptable explanation by the assessed. (5) The Department would not be justified in drawing an adverse inference only because the creditor/subscriber fails or neglects to respond to its notices; (6) the onus would not stand discharged if the creditor/subscriber denies or repudiates the transaction set up by the assessee nor should the Assessing Officer take such repudiation at face value and construe it, without more, against the assessee; and (7) The Assessing Officer is duty-bound to investigate the creditworthiness of the creditor/ subscriber the genuineness of the transaction and the veracity of the repudiation."
27. The decision in the case of Lovely Exports (supra) was considered in CIT vs. Nova Promoters and Finlease (P) Ltd. (supra) and it was elucidated:-
"38. The ratio of a decision is to be understood and appreciated in the background of the facts of that case. So understood, it will be seen that where the complete particulars of the share applicants such as their names and addresses, income tax file numbers, their creditworthiness, share application forms and share holders" register, share transfer register etc. are furnished to the Assessing Officer and the Assessing Officer has not conducted any enquiry into the same or has no material in his possession to show that those particulars are false and cannot be acted upon, then no addition can be made in the hands of the company under sec.68 and the remedy open to the revenue is to go after the share applicants in accordance with law. We are afraid that we cannot apply the ratio to a case, such as the present one, where the Assessing Officer is in possession of material that discredits and impeaches the particulars furnished by the assessee and also establishes the link between self- confessed "accommodation entry providers", whose business it is to help assessees bring into their books of account their unaccounted monies through the medium of share subscription, and the assessee. The ratio is inapplicable to a case, again such as the present one, where the involvement of the assessee in such modus operandi is clearly indicated by valid material made available to the Assessing Officer as a result of investigations carried out by the revenue authorities into the activities of such "entry providers". The existence ITA Nos. 1018/2011 & 1019/2011 Page 20 of 24 with the Assessing Officer of material showing that the share subscriptions were collected as part of a pre- meditated plan - a smokescreen - conceived and executed with the connivance or involvement of the assessee excludes the applicability of the ratio. In our understanding, the ratio is attracted to a case where it is a simple question of whether the assessee has discharged the burden placed upon him under sec.68 to prove and establish the identity and creditworthiness of the share applicant and the genuineness of the transaction. In such a case, the Assessing Officer cannot sit back with folded hands till the assessee exhausts all the evidence or material in his possession and then come forward to merely reject the same, without carrying out any verification or enquiry into the material placed before him. The case before us does not fall under this category and it would be a travesty of truth and justice to express a view to the contrary."
28. In Nova Promoters & Finlease (supra), it was held that in view of the link between the entry providers and incriminating evidence, mere filing of PAN number, acknowledgement of income tax returns of the entry provider, bank account statements etc. was not sufficient to discharge the onus.
29. In CIT v. Nipun Builders and Developers [2013] 350 ITR 407 (Del) , this principle has been reiterated holding that the assessee and the Assessing Officer have to adopt a reasonable approach and when the initial onus on the assessee would stand discharged depends upon facts and circumstances of each case. In case of private limited companies, generally persons known to directors or shareholders, directly or indirectly, buy or subscribe to shares. Upon receipt of money, the share subscribers do not lose touch and become incommunicado. Call monies, dividends, warrants etc. have to be sent and the relationship is/was a continuing one. In such cases, therefore, the assessee cannot simply furnish details and remain quiet even when summons issued to shareholders under Section 131 return unserved ITA Nos. 1018/2011 & 1019/2011 Page 21 of 24 and uncomplied. This approach would be unreasonable as a general proposition as the assessee cannot plead that they had received money, but could do nothing more and it was for the assessing officer to enforce share holders attendance. Some cases might require or justify visit by the Inspector to ascertain whether the shareholders/subscribers were functioning or available at the addresses, but it would be incorrect to state that the assessing officer should get the addresses from Registrar of Companies" website or search for the addresses of shareholders and communicate with them. Similarly, creditworthiness was not proved by mere issue of a cheque or by furnishing a copy of statement of bank account. Circumstances might require that there should be some evidence of positive nature to show that the said subscribers had made a genuine investment, acted as angel investors, after due diligence or for personal reasons. Thus, finding or a conclusion must be practicable, pragmatic and might in a given case take into account that the assessee might find it difficult to unimpeachably establish creditworthiness of the shareholders.
30. What we perceive and regard as correct position of law is that the court or tribunal should be convinced about the identity, creditworthiness and genuineness of the transaction. The onus to prove the three factum is on the assessee as the facts are within the assessee"s knowledge. Mere production of incorporation details, PAN Nos. or the fact that third persons or company had filed income tax details in case of a private limited company may not be sufficient when surrounding and attending facts predicate a cover up. These facts indicate and reflect proper paper work or documentation but genuineness, creditworthiness, identity are deeper and obtrusive. Companies no doubt are artificial or juristic persons but they are soulless and are ITA Nos. 1018/2011 & 1019/2011 Page 22 of 24 dependent upon the individuals behind them who run and manage the said companies. It is the persons behind the company who take the decisions, controls and manage them.
31. The respondent herein is a Private Limited Company. It is not the case of the respondent that the Directors or persons behind the companies making the investment in their shares were related or known to them. It is highly implausible that an unknown person had made substantial investment in a private limited company to the tune of Rs.63,80,100/- and Rs.75,60,200/- in two consecutive assessment years 2002-03 and 2003-04 respectively without adequately protecting the investment and ensuring appropriate returns. Other than the share application forms, no other agreement between the respondent and third companies had been placed on record. The persons behind these companies were not produced by the respondent. On the other hand respondent adopted prevaricate and non- cooperation attitude before the Assessing Officer once they came to know about the directed enquiry and the investigation being made. Evasive and transient approach before the Assessing Officer is limpid and perspicuous. Identity, creditworthiness or genuineness of the transaction is not established by merely showing that the transaction was through banking channels or by account payee instrument. It may, as in the present case required entail a deeper scrutiny. It would be incorrect to state that the onus to prove the genuineness of the transaction and creditworthiness of the creditor stands discharged in all cases if payment is made through banking channels. Whether or not onus is discharged depends upon facts of each case. It depends on whether the two parties are related or known to each; the manner or mode by which the parties approached each other, whether the transaction was entered ITA Nos. 1018/2011 & 1019/2011 Page 23 of 24 into through written documentation to protect the investment, whether the investor professes and was an angel investor, the quantum of money, creditworthiness of the recipient, the object and purpose for which payment/investment was made etc. These facts are basically and primarily in knowledge of the assessee and it is difficult for revenue to prove and establish the negative. Certificate of incorporation of company, payment by banking channel, etc. cannot in all cases tantamount to satisfactory discharge of onus. The facts of the present case noticed above speak and are obvious. What is unmistakably visible and apparent, cannot be spurred by formal but unreliable pale evidence ignoring the patent and what is plain and writ large.
32. In view of the aforesaid discussion the substantial question of law framed in the two appeals is answered in favour of Appellant- Revenue and against the Respondent- assessee. The appeal is accordingly allowed to the extent indicated above. The Appellant is also entitled to costs which is assessed at Rs.20,000/-
(SANJIV KHANNA) JUDGE (SANJEEV SACHDEVA) JUDGE NOVEMBER 22nd, 2013 NA/kkb ITA Nos. 1018/2011 & 1019/2011 Page 24 of 24


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