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4. Since, major factor/assets of M/s Sharda Exports is its goodwill that is why M/s Sharda Exports, Haridwar had shown to have achieved sale of more than Rs.30 crores within a short period of five months in the initial year. Since, the major assets of the firms inter alia the goodwill of the firm remained common and not transferred in writing and was not possible to be

5. The assessee did not provide the data of turnover of M/s Sharda Exports, New Delhi from 2001-02 to F.Y. 2008-09. However, Mr. Gupta accepted that their turnover of Delhi firm had decreased accordingly, due to forming the firm in the same name with Hardwar office. This shows that entire work of old Sharda Exports was shown to be shifted to Haridwar firm without executing any work at Haridwar. Even the assessee has not closed a single activity at Meerut and all the work was still being done at Meerut. All the transportation details show that the goods were being transported to Meerut and also from Meerut.