RAMAPRASADA RAO, J.

In this case the State is the petitioner. The assessee secures allotments year after year from the Director of Industries and Commerce for importing certain raw material for purposes of his business. It is common ground that the accounts of the assessee reflected the correct state of affairs and that on check of such accounts, it was found that he utilised in the course of his trade only the actual quantum of raw material granted by the Director of Industries and Commerce. But the case of the State now before us is that the assessee, year after year, was applying for a higher quota from the Director of Industries and Commerce and for this purpose he used to inflate his production in the expectancy that he would be granted a higher quota to import a higher quantum of raw material. It happened invariably that the Director of Industries and Commerce ultimately granted only less than one-fourth of the quantum applied for and this allotment was regularly and admittedly accounted for in the books of account of the assessee.

What happened in the instant case was that the assessments which were originally concluded by the assessing authorities were sought to b