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21. We have considered the rival submissions carefully and are unable to agree with the submissions of the Ld. Counsel of the assessee. First of all, no details were filed before the AO regarding trade compensation despite various opportunities. When details were filed before the CIT[A], same were sent to the AO for his remand report. AO made enquiries and issued a letter u/s.133[6] to M/s Paras Petrofills Ltd. calling for other details. The assessee was also directed to file all documents pertaining to the transaction. From the details filed by M/s Paras Petrofills Ltd. it was gathered that though they have stated that the sum of `.2,20,00,000/- was included while calculating the tax liability, but perusal of the records for A.Y 2005-06 show that nowhere income of `.220 lakhs formed part of the taxable income. The credit side of the P & L A/c. shows turnover of `.131,62,14,084/-. Other income of `.1,35,31,994/- and decrease in stock of `.3,83,12,047. note 10 of Schedule -15 of the accounts states that "Turnover include excise duty on sales, processing income and commission income but is not a part of the turnover. Further, Schedule-9 of the Other income also does not include the amount of `.220 lakhs on account of trade compensation. Therefore, it can be safely concluded that M/s Paras Petrofills Ltd. has not offered the amount of `.2.20 crores as income for A.Y 2005-06. AO further raised objection that this agreement was not on a stamp paper. He also observed that entries for the compensation were recorded on 31-3- 2005 but no payment was made during the year and payments have been made in A.Yrs. 2005-06 to 2007-08. He concluded his remand report vide para 4.1.4 which is as under: