9911796707
TMI Blog1981 (5) TMI 56X X X X Extracts X X X X X X X X Extracts X X X X ..... vious year. Assessee is an Individual. Assessee mainly derive income described as "commission" from the activity of exchange of damaged currency notes with undamaged ones. He used to collect the damaged notes atGwalior, transport them toDelhiand on certain margin of profit pass them on to person carrying similar trade atDelhi. Assessee was also liable to income-tax under the income head "income fr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ndly the addition of deemed income of Rs. 28,000 as aforesaid. The AAC deleted the said addition of Rs. 28,000 altogether and reduced the estimated addition from 1st Rs. 3,922 to Rs. 2,422 only. 4. Revenue is aggrieved from AAC's finding as to deletion of deemed income of Rs. 28,000. Facts are that having learnt that the assessee maintain a locker in the Jiwaji Chowk brank of the State Bank of In ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e and source of the said two sums, at length. ld. AAC observed that ITO's conclusions, leading to rejection of assessee's explanation as aforesaid, were based on surmises and conjectures. Cash balances, opening and closing as indicated by the assessee as for calendar years 1969 to 1971 as detailed in Para 7 of AAC's order, were taken into consideration. Assessee was found to have carried on simila ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... by the assessee not for stocking any gold or jewellery but only to put currency notes there. Lt. AAC observed that ITO avoided dealing with assessee's arguments regarding cash balance as aforesaid and also ignored various factors which want to prove the genuineness of the cash balance figures. Lt. AAC found that on enquiry into the cash balances, the ITO had found that the figures had been truly ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... and from Delhi from time to time in connection with exchange of currency notes on commission have not been indicated in assessee's books. I, consider the said argument as not being relevant to the explanation as to the nature and source of the two sums in question. The said observation was made by the ITO while determining the question of deductibility of expenses amounting to Rs. 5,628 while comp ..... X X X X Extracts X X X X X X X X Extracts X X X X
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