JUDGMENT K. K. USHA, J. – These tax revision cases at the instance of the assessee arise out of a common order passed by the Kerala Sales Tax Appellate Tribunal, Thiruvananthapuram, in T.A. Nos. 610, 611, 612, 613, 614 of 1988 and 532 of 1989. There is no tax revision case from T.A. No. 610 of 1988. 2. Relevant assessment years in T.R.C. Nos. 70 and 71 of 1994 are 1983-84 and 1984-85. For T.R.C. No. 73 of 1994 the relevant assessment year is 1985-86. As far as the assessment year 1986-87 is concerned there were two orders dated September 30, 1987 and August 22, 1988 which were subject-matter of T.A. Nos. 614 of 1988 and 532 of 1989 respectively before the Tribunal. T.R.C. No. 72 of 1994 arise from order in T.A. No. 532 of 1989 and T.R.C. No. 74 of 1994 arises from order in T.A. No. 614 of 1988. 3. The common question raised by the assessee in these revision cases are as follows : (i) Whether, on the facts and in the circumstances of the case, has the Appellate Tribunal gone wrong in holding that the revision-petitioner has been given a reasonable opportunity to raise its contentions to the pre-assessment notice ? (ii) Whether, on the facts and in the circumstances of the case, is the assessing authority bound to return the documents seized at the inspection dated April 21, 1987 after a period of 30 or 60 days as laid down under sub-section (6) of section 28 of the KGST Act ? (iii) Whether the refusal of the assessing authority to return the records seized is illegal and has resulted in a miscarriage of justice ? (iv) Whether, on the facts and in the circumstances of the case, has not the Appellate Tribunal gone wrong in not recording a finding on this contention ? (v) Whether, on the facts and in the circumstances of the case, has not the Appellate Tribunal gone wrong in sustaining the turnover assessed by the officer holding that there is no estimation by him ? (v) Whether, on the facts and in the circumstances of the case, has not the Appellate Tribunal gone wrong in sustaining the turnover assessed by the officer holding that there is no estimation by him ? (vi) Whether, on the facts and in the circumstances of the case, has the Appellate Tribunal any material to prove that all the transactions found in the seized records are suppressed sales, since there is no evidence to show that the assessing authority has conducted any independent enquiry regarding the nature of the transactions found out in the seized records in spite of the contention of the revision petitioner that these transactions are only job-works undertaken by him for his customers who have given gold for manufacturing new gold ornaments to him as goldsmith ? 4. The assessee is running a jewellery shop. The Sales Tax Officer, Chathanoor, inspected the business premises of the assessee on April 21, 1987. On verification of the seized records, it was found that sale of gold ornaments for the years 1982-83 to 1986-87 have been suppressed from the regular books of account. Proceedings under section 19 of the Kerala General Sales Tax Act, 1963, have been initiated for these five years. The escaped assessment was completed on September 30, 1987. Subsequently, another assessment under section 19 was made for the year 1986-87 as per order dated August 22, 1988. By a common order the first appellate authority dismissed all the appeals filed by the assessee. Aggrieved by the above, the assessee filed second appeals before the Tribunal. The contention put forward by the assessee before the Tribunal that no opportunity was given to him to examine the seized records was not accepted. 5. On going through the events in this case we are of the view that the Tribunal was fully justified in entering such a finding. Immediately after the seizure of the records at the time of inspection on April 21, 1977 a notice was issued on April 22, 1987 directing the assessee to produce his accounts for the years 1985-86 and 1986-87. He requested for time and the request was allowed up to May 8, 1987. Even though the assessee appeared on May 8, 1987, he did not produce books of account. The assessing officer verified the entire seized records and found that sale of gold ornaments has been suppressed in all the years. He requested for time and the request was allowed up to May 8, 1987. Even though the assessee appeared on May 8, 1987, he did not produce books of account. The assessing officer verified the entire seized records and found that sale of gold ornaments has been suppressed in all the years. A notice proposing to impose penalty under section 46(1)(c) of the Kerala General Sales Tax Act was issued to the assessee on May 15, 1987. In response to the above notice he submitted a petition requesting for an opportunity to verify the seized records so as to enable him to explain the entries therein. The assessing officer as per communication dated June 1, 1987 granted the assessee an opportunity to appear and verify the seized records on June 9, 1987. The assessee's authorised representative appeared in response to the notice dated June 1, 1987 on August 24, 1987 and verified the seized records, i.e., 13 diaries and 3 business slips. He did not raise any objection regarding the entries therein. He did not file any statement in regard to the transactions detected. Subsequently, a notice was issued on July 3, 1987 under section 19 of the Kerala General Sales Tax Act proposing to tax the turnover that has escaped assessment as revealed from the seized records. Pursuant thereto Advocate V. K. Ramachandran Nair filed vakalath on behalf of the assessee and requested the assessing authority to afford him an opportunity to verify the seized records and take down the extracts wherever necessary. Time was granted up to August 10, 1987 to verify the records. Since the advocate did not turn up a notice was issued on August 18, 1987 giving the advocate one more opportunity to verify the seized records on or before August 18, 1987. Copy of the notice was sent to the assessee also. But neither the advocate nor the assessee availed of the opportunity. The assessing officer thereupon completed the assessment for the years 1982-83 to 1986-87 under section 19 of the KGST Act. 6. The above facts are not disputed by the assessee-revision petitioner. We are of the view that the assessing authority had granted more than required opportunity to the assessee to inspect the records and take necessary notes therefrom. The assessing officer thereupon completed the assessment for the years 1982-83 to 1986-87 under section 19 of the KGST Act. 6. The above facts are not disputed by the assessee-revision petitioner. We are of the view that the assessing authority had granted more than required opportunity to the assessee to inspect the records and take necessary notes therefrom. Since the only contention pressed before us is the failure to give opportunity to the assessee to verify the records to take extract therefrom, the revision petitions are only to be dismissed. We are of the view that the Tribunal has correctly held that there was no laches on the part of the assessing authority to give proper opportunity to the assessee. The tax revision cases therefore stand dismissed. Petition dismissed.