Dismissing the appeal  the Court held that the assessee could not explain satisfactorily cash sales of Rs 3.12 crores only one month . Court applied the ratio in   Roshan Di Hatti v. CIT [1977] 2 SCC 378, the Apex Court has held that “The burden of accounting for the receipt of these assets was clearly on the assessee and if the assessee failed to prove satisfactorily the nature and source of these assets, the revenue could legitimately hold that these assets represented the undisclosed income of the assessee”, which in the instant case the assessee not to have explained to the satisfaction of the Assessing Officer.  Court also held that, it is not the case of the assessee that the product was manufactured or sold for seasonal consumption or that such sales could have been affected only in the particular months of the respective years. The satisfaction of the officer no doubt has to be based on the material so placed by the parties, which in the instant case is there. Formation of opinion has to be after accounting for all the factors and that too on objective consideration of which we have no doubt. As such, the questions of law answered accordingly and there is no merit in the present appeals which are disposed of in the aforesaid terms. (AY. 2007-08, 2008-09)