THANIKKACHALAM, J.

In both these revisions, the State is the petitioner. The assessee is V. Balu Chettiar, who is a dealer in oil and oil cakes at Thanjavur. The assessing officer while checking the accounts, has found that the gross profit disclosed was low. There was no separate account maintained for first sale of oil. The assessee had purchased oil cake from one Rajamani Trading Corporation, Trichy, to the extent of Rs. 1, 57, 835. The investigation revealed that there were no such dealers at Trichy and hence the assessing officer disallowed exemption for groundnut oil for Rs. 17, 940 and Rs. 1, 77, 564 for groundnut oil cake. The inspection in the shop on August 18, 1979, revealed stock discrepancies. The inspection of the shop on August 15, 1979 and October 16, 1979, revealed sales without issue of bills. The purchase bills of 9, 640 tins of vanaspati and 368 bags of cotton seeds revealed that out of the 150 tins remaining, the value was ascertained and assessed above the total taxable turnover at Rs. 22, 86, 221 and Rs. 5, 72, 966 respectively. Penalty of Rs. 10, 398 also was levied for the suppression.

2. Against the addition of Rs. 2, 87, 364 and levy of penalty