ORDER PRAKASH SHRIVASTAVA, J. - This order will govern the disposal of W.P. No. 5873 of 2008 and W.P. No. 5874 of 2008. In W.P. No. 5873 of 2008, the petitioner has challenged the assessment order dated January 29, 2007, (annexure P7) as affirmed by the revisional order dated June 16, 2008, passed under the Madhya Pradesh Commercial Tax Act, 1994, for the period April 1, 1999 to March 31, 2000 and in W.P. No. 5874 of 2008 the petitioner has challenged the assessment order dated January 29, 2007 (annexure P7), as affirmed by the revisional order dated June 16, 2008 passed under the Madhya Pradesh Sthaniya Kshetra Me Mal Ke Pravesh Par Kar Adhiniyam, 1976 (for shot, "the Entry Tax Act") for the period of April 1, 1999 to March 31, 2000. Both the writ petitions are on the same facts and grounds, therefore, disposed of by a common order. The case of the petitioner is that it is a registered firm constituted for the purpose of business of purchase and sale of vanaspati ghee and it obtained the import/export licence from the Government with a view to import vanaspati ghee from Nepal. Undisputedly, the petitioner imported vanaspati ghee from Nepal for sale in Madhya Pradesh. The case of the petitioner is that he had submitted the monthly returns for the period he had imported and sold vanaspati ghee in Madhya Pradesh. During the assessment proceedings, the assessing authority relied upon the information received by him and came to the conclusion that the petitioner had imported and sold in Madhya Pradesh much more quantity of vanaspati ghee, than, what was disclosed in returns. The assessing authority vide order of assessment dated January 29, 2007, found additional turnover of Rs. 5,75,93,995 of which vanaspati ghee was allegedly imported and sold by the petitioner. On this value, the assessing authority levied commercial tax and entry tax and also levied penalty. The petitioner preferred a revision before the Additional Commissioner, Commercial Tax, who by order dated June 16, 2008 (wrongly mentioned as June 16, 2006) dismissed the revision petitions and upheld the levy of tax and penalty under the Commercial Tax Act and Entry Tax Act. The petitioner preferred a revision before the Additional Commissioner, Commercial Tax, who by order dated June 16, 2008 (wrongly mentioned as June 16, 2006) dismissed the revision petitions and upheld the levy of tax and penalty under the Commercial Tax Act and Entry Tax Act. The learned counsel appearing for the petitioner submitted that the liability of entry tax and commercial tax has wrongly been fixed on the petitioner since, there was no sufficient material to connect the petitioner with the alleged import of vanaspati ghee from Nepal. He further submitted that it is not established from the material on record that the alleged vanaspati ghee was brought into the State of Madhya Pradesh and sold by the petitioner, therefore, he cannot be held to pay commercial tax as well as entry tax on the alleged turnover, as assessed by the assessing authority. He submitted that the order of assessment is based upon the information collected behind his back and the burden has wrongly been placed on him. As against this, learned counsel appearing for the respondents submitted that the assessing as well as revisionary authority, on the basis of the material collected by them have rightly assessed the turnover of the petitioner and levied entry tax and commercial tax. He further submitted that the entire material was disclosed to the petitioner in pursuance of earlier remand order and no error has been committed by the authorities in placing the onus on the concerned party while making the assessment and on the basis of the material, the finding has rightly been recorded that the petitioner had imported and sold vanaspati ghee in the State of Madhya Pradesh, holding him liable to pay commercial tax and entry tax. We have heard the learned counsel for the parties and perused the record. The revisional authority in the impugned order dated June 16, 2008 has elaborately dealt with the issue and examined the material before upholding the liability of the petitioner. The order passed by the revisional authority is an elaborate and well reasoned order. The revisional authority, on the basis of the material on record has recorded findings and the scope of interference in the factual findings recorded by the revisionary authority is limited unless the findings are shown to be perverse. The order passed by the revisional authority is an elaborate and well reasoned order. The revisional authority, on the basis of the material on record has recorded findings and the scope of interference in the factual findings recorded by the revisionary authority is limited unless the findings are shown to be perverse. It is not disputed that the petitioner had obtained the import licence and had imported some quality of vanaspati ghee from Nepal. The dispute is about the additional turnover which has been found by the assessing and revisional authority. The disputed turnover relates to the vanaspati ghee, which was imported in the name of the petitioner. On the basis of the information collected from Divisional Deputy Commissioner, Commercial Tax, Ujjain, the revisional authority found that vanaspati ghee in such a manner was imported not only by petitioner, but others such as M/s. Malwa Kakri Centre, Dewas, M/s. Rupam Fashion International, Indore also. On the basis of the correspondence between the revisional Deputy Commissioner, Commercial Tax, Ujjain and incharge Deputy Commissioner, Commercial Tax, Bihar, he found that this vanaspati ghee was transported from Nepal through Muzaffarpur. The trucks, which were captured by officers of Bihar in respect of them, the concerned unit of Madhya Pradesh made admission. The revisional authority found that the petitioner and other two local dealers were involved in the import of vanaspati ghee in the similar manner. In the original record for some of the imports, which have been admitted by the petitioner, the invoice and other details are on record and in respect of the disputed turnover, the vehicle number, quantity of vanaspati ghee and its value and the date on which the import was made are available. In respect of all these imports the consignee is the petitioner. When so much of material was brought on record against the petitioner, the petitioner had an opportunity to contact the consignor whose details were disclosed and place some evidence to rebut those material and to show that the quantity and the value disclosed in these documents in respect of import of vanaspati ghee was wrong or the petitioner had not imported those vanaspati ghee. The petitioner has raised the ground that the information provided by Avadh Pratap Singh, cannot be relied upon because Avadh Pratap Singh has not been cross-examined and he had made an attempt to blackmail the petitioner. The petitioner has raised the ground that the information provided by Avadh Pratap Singh, cannot be relied upon because Avadh Pratap Singh has not been cross-examined and he had made an attempt to blackmail the petitioner. This aspect of the matter has been dealt with by the revisional authority by noting that the Divisional Deputy Commissioner, Commercial Tax, Indore had received 12 documents, which includes the bilty bill of licence, export licence, copy of bill prepared by M/s. Sushil Vanaspati Pvt. Ltd., Parvanipur Parsa, Nepal in the name of the petitioner. It also includes a letter written in the letter head of the petitioner to the Assistant Commissioner, Commercial Tax, Investigation, Tirhut Range, Muzaffarpur, in which a request was made to release the trucks, which were transporting the ghee in the name of the petitioner. A list is also on record prepared by the Customs Raxol, which has estimated the value of transported goods at Rs. 5,75,93,995. The assessing authority and the revisional authority on the basis of all these material have found that the petitioner had imported the vanaspati ghee in question and on the basis of the material so collected they had fixed the liability of entry tax and commercial tax on the petitioner. The petitioner has challenged the impugned orders on the ground that the material relied upon by the assessing authority was not disclosed to the petitioner, but the record indicates that the assessing authority had earlier passed the assessment order dated January 17, 2003, which was challenged by the petitioner before the revisional authority and the order of assessment was set aside by the revisional authority by order dated January 27, 2004, finding that the petitioner was not disclosed the material collected and was not given proper opportunity. While remanding the matters, the revisional authority had directed to provide the petitioner copies of the information received and to give the petitioner an opportunity to adduce the other evidence, which he wanted to give in support of his case and pass fresh order by following the principles of natural justice. Thereafter, the fresh order has been passed by the assessing authority by giving an opportunity and complying with principles of natural justice. The petitioner's plea that material relied upon by the authority was not disclosed to the petitioner has no merit. Thereafter, the fresh order has been passed by the assessing authority by giving an opportunity and complying with principles of natural justice. The petitioner's plea that material relied upon by the authority was not disclosed to the petitioner has no merit. The petitioner has also challenged the impugned order on the ground that the burden was on the Department to collect the material and onus has wrongly been fixed on the petitioner. In the present matter, the Revenue had collected the material and assessing and revisional authorities after taking note of number of documents have found that the petitioner had imported disputed quality of the vanaspati ghee from Nepal, which was transported through different vehicles, the details of which are also on record. Under rule 48(2) of the Madhya Pradesh Vanijya Kar, Adhiniyam, 1995, the assessing authority is required to assess the dealer to tax on the basis of the objection raised by the dealer, evidence adduced by him and such other evidence as may be available. In the case of this nature, where, the dealer had allegedly clandestinely brought the goods in the State, after importing it from neighbouring country, it may not be possible to collect the direct evidence of the entry or sale of goods. The petitioner in the writ petition does not dispute that some quantity of vanaspati ghee was imported by him. He also does not dispute that the vanaspati ghee was imported on the basis of the import licence issued to the petitioner, but his plea is that his agent misused the import licence issued in the name of the petitioner. When the petitioner had raised such a plea, it was necessary for him to adduce some evidence in support of his plea to escape the liability of commercial tax and entry tax which he failed to do. The petitioner admits that the vanaspati ghee in question was imported, using his imported licence. Therefore, it is not open to him to state that there is no nexus between the import and sale of vanaspati ghee and the petitioner. The petitioner admits that the vanaspati ghee in question was imported, using his imported licence. Therefore, it is not open to him to state that there is no nexus between the import and sale of vanaspati ghee and the petitioner. In the case on hand the assessing authority on the basis of the material collected by the Revenue has fixed the liability of commercial tax and entry tax on the petitioner by reaching to the conclusion that the entry and sale was effected by the petitioner and such a finding does not appear to be perverse or unsupported by material, therefore, it is not required to be interfered with. That in view of the above analysis, we do not find any merit in the writ petition and the same is accordingly dismissed. No orders as to cost.