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TMI Blog1989 (3) TMI 62X X X X Extracts X X X X X X X X Extracts X X X X ..... er, on the facts and in the circumstances of the case, the Tribunal ignored relevant materials and relied on irrelevant materials in holding that the nature and source of the sum of Rs. 1,36,300 credited to the account of Smt. Laxmimoyee Sen has been satisfactorily explained by the and whether acceptance by the Tribunal of the sale of ornaments to Imperial Bullion Co. was based on no evidence ? ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the nature and source of the cash credit of Rs. 25,000 in the account of Smt. Laxmimoyee Sen? (2) If the answer to question No. 1 is in the affirmative, then, whether, on the facts and in the circumstances of the case, the Tribunal was justified in deleting the addition of Rs. 25,000 and in allowing the interest credited to the account of Smt. Laxmimoyee Sen ?" All the three appeals were di ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ver, did not accept the explanation of the lady and the loan amounts were added back to the income of the assessee. The appeal preferred against the assessment orders went up to the Tribunal. The Tribunal took into account the fact that the Commissioner had passed an order under section 33B of the Indian Income-tax Act, 1922, as early as in 1963. Eleven years had passed but the assessments of L ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... herefore, we answer the questions as under In respect of the assessment year 1960-61, we answer question No. 1 in the negative and in favour of the assessee. In view of the answer given to question No. 1, question No. 2 does not arise and need not be answered. In respect of the assessment year 1961-62, we answer the question in the negative and in favour of the assessee. In respect of ..... X X X X Extracts X X X X X X X X Extracts X X X X
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