Maintenance Of Records, Data Compilation & Issues In Vat Audit

Transcription

1 Maintenance Of Records, Data Compilation & Issues In Vat Audit 26 th November 2014 DILIP PHADKE Chartered Accountant Contact: /

2 IMP. DEFINATIONS SEC. 2 10) "Document" includes electronic record as defined in the I. T. Act, 2002; RANDOM HOUSE DICTIONARY defines document as written or printed paper furnishing information or evidence, it can be a deed, a legal or official paper, it can be in the form of letter, article or books. It contains factual information. It means evidence or proof it can substantiate the claim or the data. 18) Place of business includes a warehouse, godown or other place where a dealer stores his goods and any place where the dealer keeps his books of accounts.

3 IMP. DEFINATIONS SEC. 2 20) Purchase price: To include amt. payable for anything done by seller before delivery including central excise, customs deposit paid whether refundable or not but shall exclude transit insurance, installation charges, tax paid or payable. Duties under Central excise, customs act, or Bombay prohibition act shall be included. It shall not include Vat payable on purchase. Deposit in connection with or incidental or ancillary to the purchase, whether refundable or not shall be included.

4 Maintenance of records(sec.63) (4) Every registered dealer shall ordinarily keep all his accounts, registers and documents relating to his stocks of goods, or to purchases, sales and delivery of goods made by him or payments made or received towards sale or purchase of goods, at the place or places of business specified in his certificate of registration or with the previous approval of the Commissioner, at such other place as may be agreed to by the Commissioner

5 (1) Every dealer liable to pay tax under this Act, and any other dealer, required to do so by the Comm., shall keep a true account of the value of the goods sold or purchased by him. (2) If the accounts kept are not sufficiently clear or intelligible to enable him to determine whether or not a dealer is liable to pay tax during any period, or are so kept as not to enable a proper scrutiny of the returns or the Statements furnished, the Comm. may require such dealer by notice in writing to keep such accounts, of sales or purchases in such form or manner as in his opinion is necessary for the purpose of proper quantification of tax

6 Maintenance of records(sec.63) (3) The Commissioner may, subject to such conditions or restrictions as may be prescribed in this behalf, by notice in writing direct any dealer, or by notification in the O.G., direct any class of dealers, to maintain accounts and records giving necessary details of sales, purchases etc. (5) Where,- any sales are returned or purchases are returned within the prescribed time, then the goods returned shall be accounted for in the return for the period in which appropriate entries are taken in the books of account

7 Maintenance of records(sec.63) (6) If the sale price or, as the case may be, the purchase price of any goods is varied and credit notes, or as the case may be debit notes, are required to be issued to give effect to such variation, then,-- the credit notes or, as the case may be, debit notes shall separately specify the component of tax, if any, and the component of price, and shall be accounted for in the return in the period in which appropriate entries for debit notes and credit notes are taken in the books of account.

8 PRODUCTION OF ACCOUNTS Sec. 64 (1) The Comm. may, subject to such conditions as may be prescribed, require any dealer to produce before him any accounts or documents, or to furnish information, relating to stocks, sales, purchases and delivery of goods or receipts, payments towards sales or purchases or any other information relating to his business, as may he necessary for the purposes of this Act. (2) All accounts, registers and documents relating to stock purchases, sales and delivery of goods, receipts & payments towards sale or purchase of goods by any dealer and all goods

9 and cash kept in any place of business of any dealer, shall at all reasonable times, be open to inspection by the Comm., and the Comm. may take or cause to be taken such copies or extracts of the said accounts, registers or documents and such inventory of the goods and cash found as appear to him to be necessary for the purposes of this Act. (3) If the Comm. has reason to believe that any dealer has evaded or is attempting to evade the payment of any tax due from him, he may. for reasons to be recorded in writing, seize such accounts, registers or documents of the dealer as may be necessary, and shall grant a receipt for the same,

10 and shall retain the same for so long as may be necessary in connection with any proceedings under this Act or for any prosecution: Provided that, on application of the dealer, the Comm. shall provide true copies of the said accounts, registers or documents. (4) For the purposes of sub-section (2) or subsection (3), the Comm. may enter and search any place of business of any dealer or any other place where the Comm. has reason to believe that the dealer keeps or is for the time being keeping any accounts, registers or documents of his business or stocks.

11 5) Where any books of accounts, other documents. money or goods are found in the possession or control of any person in the course of any search, it shall be presumed unless the contrary is proved, that such books of accounts, other documents, money or goods belong to such person. Explanation.: For the purposes of this section, place of business includes a place where the dealer is engaged in business, through an agent by whatever name called or otherwise, the place of business of such agent. a warehouse, godown or other place where the dealer or the agent stores his goods and any place where the dealer or the agent keeps the books of accounts.

12 69. Retention of books of accounts. If the Comm. seizes any books of accounts, registers or documents of any dealer under section 64, he shall not retain them for more than twenty one days without recording his reasons in writing for so doing. Provided that, where an officer below the rank of Jt.Comm. seizes any books, etc. by virtue of powers of the Comm. under section 64 delegated to him, he shall not retain them, or cause them to be retained, for a period

13 69. Retention of books of accounts exceeding one year unless an officer not below the rank of Jt.Comm. having jurisdiction over the local area in which the place of business of the dealer is situated, has for reasons to be recorded in writing, authorize the retention of the books, registers or documents so seized for a longer period : ( provided further that, such longer period shall not be more than one year at a time.)

14 PENALTY (Sec.29) (4) Where any person or dealer has knowingly issued or produced any document including a false bill, cash memorandum, voucher, declaration or certificate by reason of which any transaction of sale or purchase effected by him or any other person or dealer is not liable to be taxed or is liable to be taxed at a reduced rate or incorrect set-off is liable to be claimed on such transaction, the Commissioner may, after giving the person or dealer a reasonable opportunity of being heard, by order in writing, impose on him in addition to any tax payable by him, a penalty equal to the amount of tax found due as a result of any of the aforesaid acts of commission or omission.

15 Tax Invoice Sec. 86 Every registered dealer selling Taxable goods MAY issue a tax invoice and retain a copy for 3 years from the end of the year to which it relates. Tax invoice shall contain the following details: The words Tax Invoice in bold letters at the top Name, address and registration no. of the selling dealer Name and address of purchasing dealer. Individual serialised number and date of invoice. (Not specified whether to be pre-printed).

16 Tax Invoice Contd. Description of goods, quantity or number, price of the goods sold and amount of tax charged thereon indicated separately Signature of the dealer or the authorised person. Each Tax Invoice should have certificate with specified wordings The Dealer may either issue a cash memo or a bill instead containing the particulars as may be prescribed.

17 Tax Invoice contd.. The dealer has to issue either TAX INVOICE OR BILL for all sales. The State Government may provide rules for electronic system of maintaining copies of invoices or cash memorandum on the conditions as may be specified. On such occasion the dealer may keep records and copies in such electronic media after the permission is received. (Section 86)

18 Declaration on TAX INVOICE I / We hereby certify that my/our registration certificate under the Maharashtra Value Added Tax Act, 2002 is in force on the date on which the sale of the goods specified in this tax invoice is made by me / us and that the transaction of sale covered by this tax invoice has been effected by me / us and it shall be accounted for in the turnover of sales while filing of return and the due tax, if any, payable on the sale has been paid or shall be paid.

19 DECLARATION BY EXEMPT UNIT "I/We hereby declare that sale of goods evidenced by this invoice is exempt from the whole of sales tax in my/our hands on account of the Certificate of Entitlement bearing No. duly granted to me/us and as such my/our immediate purchaser shall not be entitled to claim any set-off in respect of this transaction under any provision of Maharashtra Value Added Tax Act, 2002 or the rules framed thereunder and that the transaction shall be accounted for in the turnover of sales while filing my return.

20 PENALTY (Sec.29) (6) Where, any person or dealer contravenes the provision of section 86, so as to have the quantum of tax payable by him to be underassessed, the Commissioner may, after giving the person or dealer a reasonable opportunity of being heard, by order in writing, impose on him, in addition to any tax payable by him a penalty equal to half the amount of tax which would have been under-assessed or one hundred rupees, whichever is more.

21 REQUIREMENTS OF A/C Form 404 In the case of works contract the employer who deducted tax at source under MVAT, is required to maintained register under Form No Form 404 contains the following points: 1. Sr. No. 2. TDS Certificate No. 3. Date of Certificate. 4. Period to which certificate relates. 5. Name and Address of Contractor to whom certificate is issued.

22 Form 404 Cont. 6. R.C. No. of the dealer executing works contract, if any. 7. Amount collected or paid towards works contract executed during the period. 8. Amount of Tax deducted. 9. Amount paid. 10. Challans No. and Date. 11. Name and Address of Government Treasury/ Bank.

23 Rule 52. Claim & Grant of Set off on Purchases The Comm. in respect of purch. made on or after Appointed day, grant set off of the aggregate of the following sum: 1 Tax paid by claimant dealer on purch. of capital goods and purch. of goods which are dr. to P & L A/c, trading goods, R.M., parts etc. 2 Tax paid in respect of any entry made under the Maharashtra Tax on the Entry of Motor Vehicles/goods 3 Purchase tax paid by dealer.

24 R 55 Condition for grant of set off No set-off or refund shall be granted to a dealer in respect of any tax recovered from him on the purchase (a) unless the goods are purchased or entry is effected on or after the 1st April of the year in which the dealer has obtained registration and, (1) The goods are treated as capital assets and not been sold before the date of effect of registration, or (2) The other goods have not been sold before the date of effect of registration, or (3) The other goods and have been used or consumed in manufacture and the manufactured goods have not been sold before the date of effect of registration, or (4) The dealer was a registered dealer at the time of such purchase or entry

25 2) Dealer shall maintain true account in chronological order of all the purchases in the form of purchase register. 3) Dealer shall produce the tax invoice, bill before comm. As & when required. (5) Where the claimant dealer is unable to identify the goods purch. with the goods resold or with the goods used in the manufacture of goods or in the packing of goods, it shall be presumed for the purpose of reduction or disallowance of set off that the goods so purch. have been used or consumed in the chronological order in which they were acquired before or after appointed day.

26 (a) Where a dealer has filed a return in respect of any period contained in a year, then he may, adjust the aggregate of (i) Any payment made of the said period before filing of return, (ii) The total value of the T.D.S. certi. received in that period, (iia) the total value of the Tax collection certi. received by him in that period, and (iii) the amount of refund adj. order issued in respect of period. (iv) set-off or refund to which the dealer has become entitled in the said period. (v) Deposit paid towards voluntary registration. (A) Against the tax payable according to the said return, or (B) Against the tax payable according to the return for the said period filed by him under the Central Sales Tax Act, 1956, or (C) Against the tax payable according to the return which may be due or may become due under the Maharashtra Tax on Entry of Goods into Local Areas Act, 2003.

27 (b) If after making adjustment, if any, as provided in clause (a), there be any excess, then the dealer may claim refund of the excess or part of excess in accordance with the rules, or carry forward the same for adjustment towards the tax payable as per the returns to be filed for any subsequent period contained in the said year under MVAT, C.S.T, or entry of goods act. (4) Dealer who is entitled to a refund under these rules or, as the case may be, under any earlier law, the amount so due by way of refund, shall first be applied towards the recovery of the amount Where a notice under sub-section (4) of section 32 has been issued for the payment of any sum by a dealer or the dealer has filed any return or revised return without full payment of tax and the balance amount, if any, shall thereafter be claimed as refund.

28 (6) Set-off of the tax paid under the Tax on Entry of Motor Vehicles /goods into the Local Areas shall be granted to a dealer as if such tax is a tax levied under this Act or, as the case may be, and all of the provisions of these rules including those relating to reduction in s/o & non-admissibility of s/o shall apply accordingly. 7)Where a dealer liable to pay tax (i) dies and the business in which the dealer was engaged is continued after his death, by any person or persons, (ii) Trf. Or disposes of his business or effects any change in the ownership thereof, in consequence of which he is succeeded in the business or part thereof, by any other person, then the person succeeding shall be entitled to take credit of any s/o that is carried forward, if any, at the time of the said death, transfer, disposal or change

29 R 57: Reduction of sale price Dealer can reduce sale price if it is including tax. Amount of deduction is = R/100+R this benefit is not be available for purchase price. Amount of Purchase including packing material from exempt unit would be allowed as reduction from Sales Price. VAT is to be paid on the balance amount only. In case goods manufactured by exempt units and sold through trading channels, tax will be collected and paid only on value addition net of sale price of the exempted unit. A the bill for machinery was for net Rs plus vat Rs. 625/- total Rs. 50,625/- now it is to be sold for Rs.55,000/- plus tax calculate the amt. of tax payable.

30 Rule 58. Sale price of WCT transactions Value of goods at the time of transfer of property in goods in WCT may be determined after the following deductions: Labour charges for execution of works. Amount paid to sub-contractors. Charges for planning, designing and architect fees. Hire charges of machinery or tools used.

31 Rule 58. Sale price of WCT transactions Cost of consumables such as water, electricity, fuel etc. used. Cost of establishment of contractor. Other similar expenses relatable to supply of labour & services. Profit earned relatable to supply of labour & services.

32 EFFECT OF NON MAINT. OF A/C R.58 If the contractor has not maintained a/c which unable a proper evaluation of the diff. deductions as above or where the Comm. finds that the a/c are not sufficiently clear or intelligible, the contractor or the Comm. as the case may, in lieu of the deductions as above provide a lump sum deduction as provided in Table in point 1 to 14and determine sale price accordingly.

33 Rule 59. Taxable Turnover of Sales of residential hotel charging a composite sum In assessing the turnover of sales of residential hotels, providing lodging and boarding and charging a composite sum, the Comm. shall determine the turnover of sale as certain percent of the composite charges as provided in this rule in point (a) to (g).

34 EFFECT OF NON MAINT. OF A/C RULE 59 If the claimant dealer produces evidence to the satisfaction of the Comm. that the component of the taxable turnover of sales in the composite sum is less than the percentage given, the Comm. shall reduce the above percentage to the extent of actual sum of turnover of sales, so proved.

35 Preservation of records R. 68. Every registered dealer shall preserve all books of accounts, registers and other documents relating to the stocks, purchases, dispatches and deliveries of goods and payments made towards sale or purchase of goods for a period of not less than five years from the expiry of the year to which they relate.

36 ICAI Guidance Note Input tax credit is available on purchases, capital goods & amt. dr. to profit & loss a/c Input Tax credit (ITC) is available on local purchases & not on O.M.S. purchases. If ITC is more than the taxes payable, carry it forward upto year end and claim refund. Exempt units entitled for refund. No ITC available if product sold is exempt but available if tax rate is zero.

37 Treatment of purchases/ stock The purchases should be accounted net of tax & tax paid on such purchases should be debited to separate account. The tax on input shall not be treated as expenses, whenever it is adjusted against tax payable on sales, adjustment entry should be passed crediting input tax & debiting tax payable.

38 Treatment of purchases/ stock If ITC is disallowed it shall be added back to purchases and included in inventory (if left),otherwise shall be debited to P & L a/c Any refund of ITC received should be credited to ITC Receivable a/c and not shown as income. Purchases & inventory of the material purchased from URD/ Composition dealers shall be accounted net of tax.

39 Treatment of purchases/ stock Any other material debited to P & L a/c shall be accounted on net of tax basis & tax on the same shall be credited to a separate account, VAT credit receivable Account. ITC shall be kept in separate account & adjusted against VAT payable, any bal. left at the year end shall be shown as Loans & Advances.

40 Treatment for Capital Goods Capital goods should be valued at its cost of purchases + duties or taxes + exp. for installation but it exclude VAT which should be credited to separate a/c. The depreciation shall be provided on net amount excluding VAT. If any VAT is disallowed it shall be added to the cost of assets on the date of disallowance and dep. provided prospectively.

41 Contrary Provision in I. T. Act According to section 145A of the Income Tax Act, 1961 the purchases and sales shall include taxes paid or collected. This is against the Guidelines issued by ICAI for Accounting Treatment which states that Purchase and Sale as well as Stock should not include VAT paid or collected which should not be debited to Profit and Loss A/c i.e. it should be shown in other separate a/c.

42 Treatment for Sale Tax collected on sales shall not be recognized as income and shown in a separate account VAT payable. If any VAT is paid it shall not be treated as expense It is adjusted against VAT Payable account If any balance left payable in VAT payable Account after adjustments it shall be shown as current liability

43 Treatment for Sale Unit under incentives opting for deferral shall show tax collected & payable as long term liability. If any Enterprises is not collecting tax separately (composition scheme) the liability on account of VAT Payable should recognized on periodic basis and sale to be accounted net of VAT.

44 DATA COMPILATION Basic Requirements of Part I & Part II of Form 704 NAME OF THE CLIENT: CONSTITUTION: TIN NO.: CST NO.: JURISDICTION: CONTACT NO: NAME OF THE VAT AUDITOR.:

45 Sr. Particulars No 1 Finalised Accounting Data with Final Accounts Remarks 2 Tax Audit Report 3 Statutory Audit Report (only for Corporate Clients) 4 Copy of RC of MVAT & CST along with Periodicity (Client Details from Know Your TIN) 5 Copy of VAT / CST Returns & Challans

46 Sr. Particulars No. 6 Whether Stock Register is maintained Remarks 7 Stock Statement showing Bifurcation of Stock 8 Applicable Schedules Schedule I (Form 231) Schedule II (Form 232) Schedule III (Form 233) Schedule IV (Form 234) Schedule V (Form 235) Schedule VI (Form III E)

47 Sr. Particulars No. 9 Applicable Annexure Annexure A (Details of MVAT Payment) Annexure B (Details of CST Payment) Annexure C (Details of WCT Certificates received) Annexure D (Details of WCT Certificates issued) Annexure E (Details of Set off to be taken) Annexure F (Financial Ratios) Annexure G (Details of Declarations Received) Annexure H (Details of H Form in Local not Received) Annexure I (Details of Declarations not Received) Annexure J1 (Customer VAT TIN Wise Sales) Annexure J2 (Supplier DILIP VAT PHADKE(C.A.) TIN Wise Sales) Remarks

48 Sr. No. Particulars Annexure J5 (Details of Export & High Sea Sales) Annexure J6 (Details of Import & High Sea Purchases) Annexure K (Reconciliation) Remarks 10 Read reporting paras and answer each point 11 & Telephone No's of the Dealer 12 PAN Card Copy of the Client 13 Trade Name (if any)

49 Sr. No. Particulars 14 & Telephone No's of the Dealer Remarks 15 Professional Tax (RC No.) Copy of Registration certificate of PT Check challans of PT Paid & keep copy of March Challan 16 Professional Tax (EC No.) Copy of Registration certificate of PT Check challan of PT Paid & keep copy of Challan 17 Luxury Tax No. (if applicable)

50 Sr. No. Particulars Check challans of LT Paid & keep copy of March Challan 18 ECC No. under Central Excise (Ask for Reg'n Certificate Copy) Remarks 19 Import Export Code (Ask for Reg'n Certificate Copy) 20 Service Tax No. (Ask for Reg'n Certificate Copy) 21 Business Activity (from VAT / CST Registration Certificate)

51 Sr. No. Particulars 22 Commodity dealt in (from VAT / CST Certificate) Remarks 23 Address where Books of Accounts are kept 24 Specify if any Changes in : Accounting Software, Stock Valuation, Accounting System, Product Line. Other Changes. (If Any)

52 Sr. Particulars No. 25 Nature of Business. (Tick the Applicable Fields in Form) Remarks 26 Working Capital (as per Compilation) 27 Activity Code (Keep a copy of the activity code applicable) 28 Bank Statements (Check & Keep a copy the Bank Statements & Bank Reconciliation of March )

53 Sec. 61. Tax Audit 1) Every dealer liable to pay tax shall, (a) if the (i) turnover of sales & value of goods trf. To any other place of his business or his agent or principal, situated outside the state, not by reason of sale, or, (ii) turnover of purchases, exceeds rupees one crore in any year, or (c) If he holds an entitlement certificate in respect of any P.S.I., granted under MVAT OR B.S.T. G Get his accounts in respect of such year audited by an Accountant within the prescribed period from the end of that year and furnish within that period the COMPLETE report of such audit in the prescribed form duly signed and verified by such accountant and setting forth such particulars and certificates as may be prescribed.

54 Sec. 61. Tax Audit Explanation-I - For the purposes of this section, Accountant means a Chartered Accountant Cost accountant or Company Secretary. Explanation-Complete audit report means if all the items, certifications, tables, schedules and annexure are filled appropriately and are arithmetically self consistent. (2) If any dealer liable to get his accounts audited u/s/s (1) fails to furnish a copy of such report within the time as aforesaid, the comm. may, after giving the dealer a reasonable opportunity of being heard, impose on him, in addition to any tax payable, a sum by way of penalty equal to 1/10% of the total sales.

55 Sec. 61. Tax Audit (2) If any dealer liable to file audit report under this sec. Knowingly furnished the audit report which is not complete, the comm. may, after giving the dealer a reasonable opportunity of being heard, impose on him, in addition to any tax payable, a sum by way of penalty equal to 1/10% of the total sales. (3) This sec. shall not apply to Dept. Of union govt. or state govt., local authorities, Railways, Konkan railway, M.S.R.T.C.

56 POSERS 1) A dealer having turnover of calibrations of more than fifty crores has used consumables of 75 lacks, Purchases are one crore. In bills he has shown sale of 18 lacks for parts used. Whether he is liable for registration? If he takes voluntary registration whether Vat audit is necessary? 2) While doing the assessment of a dealer who is doing job work the assessing officer points out that there is a taxable purchase of 80 lacks shown by another dealer from him and there is a mismatch of J-1/ J-2 & charges penalty for non filing of audit report. 3) What are to be precautions to be taken while allowing claim for O.M.S. branch transfer, including provision of reduction of set off.

57 4) A dealer took registration late after he crossed the required turnover. What will be the set-of position for the period when he actually crossed the required turnover and the date he got registration (URD Period)? What is the remedy to the dealer? What are the chances that he will get administrative relief? 5) The dealer sells an item X. Subsequent to the sale, the goods are not found as per specification. The dealer has agreed to take back goods partially & offer some discount on the goods retained by the customer. For goods returned & reduction in price credit note is issued showing value of goods returned & additional discount offered. Can dealer claim the discount offered by reducing it from the sales turnover in the period in which the discount is offered? 6) What are the provisions of MVAT Act vis-à-vis Freight Charges charged to customers either by way of Separate Debit Note or shown separately in Bill. Whether it forms part of Sales Price for VAT?

58 7) How to give effect for Debit Note/Credit Note for tax difference: i.e. where the dealer has charged 12.5% instead of 4% & subsequently given CN for 8.5%? What if CN was given in subsequent financial year? 8) Now it is settled that builder is works contractor, is he liable to deduct TDS on sub contracted portion? 9) Can VAT auditor revise audit report? 10) Sales promotional items are purchased on C form whether there is any contravention? 11) An item of 12.5% is purchased from trader. The bill shows Rs. 1,00,000/- Net plus Tax of Rs. 3,750/-. How to show Set off in Sch. I of Audit Report? What should be the tax charged while if material is sold for 1,20,000/-? 12) How to treat WCT deducted bycontractee & TDS certificates is received / not received?

59 13) Computer/server is Installed in a office and used by the two Associate Concerns. Both are Registered Dealers. The Concern owning the Computer raises debit note on other concern for charges for use at the year end. Whether the same is liable to tax? 14) Purchases are made from outside Maharashtra and delivered outside Maharashtra. The Sale bill is made in Maharashtra; Whether Such Turnover is to be included in Turnover of Maharashtra? 16) What are the obligations of an employer of a contractor who is reg./nonreg. under MVAT, but liable to deduct and pay the T.D.S. do the same?

60 15) Dealer is a Government Works Contractor. The bills issued by the Dealer are not considered by Government. Work Measurement and value entered by the Government engineer in measurement book (MB), which is in the custody of the Government. Copy of MB is available with the Dealer, which is given to the Dealer along with Cheque (Net Amount after deduction for expenses, retention money, IT TDS, WCT TDS). Dealer works out the turnover on the basis of the terms of payment particulars and TDS certificates (IT & WCT) at year end. How to verify turnover? What Observations or remarks to be mentioned? 17) A tyre mfg.sold the tyre against replacement warranty for one year. Car user comes to Mfg. for replacement of tyre within the warranty period as well as after the warranty period. In the Sale bill the value of old tyre are deducted from S.P. under the head Claim Loss and VAT charged on net amount, whether practice is correct?

61 18)A machinery manufacturer sales a machine under replacement warranty through a dealer situated O.M.S. The dealer replaces the part of the machine from his stock in warranty period. The bill does not show the part as sale and nothing is recovered from customer. The manufacturer sends dealer credit note for the value of the part less scrap value. The dealer deducts the credit note amount from purchases. Is the treatment by the manufacturer and dealer correct? 19) A textile processor does the job work and makes the bill for processing charges of gray cloth received from others. He is also doing laundry business. The sale bills of processing are 49% & laundry 51% of turnover. Which rule will be applicable to him? Rule 53(6) receipts on account of sale less than 50%, Rule 53(10) dealer executing contract for processing of textile or Rule 54(d) dealer principally engaged in doing job work. 20) When the service tax and DILIP Vat PHADKE(C.A.) both are chargeable on sale transaction?

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