TMI Blog1981 (12) TMI 9X X X X Extracts X X X X X X X X Extracts X X X X ..... ate Tribunal in this reference under s. 256(1) of the I.T. Act, 1961, is as follows : " Whether, on the facts and in the circumstances of the case, and having regard to the provisions of section 68 of the Income-tax Act, 1961, the Tribunal was justified in confirming the deletion of the amount of Rs. 27,800 considered for assessment as the income of the assessee from undisclosed sources ? " Th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... necting the cash credit deposits with the intangible additions. The Tribunal observed that circumstances did exist to connect the two and that the assessee had excess funds in the form of disallowed expenses and these funds were introduced as alleged cash credits. In the opinion of the Tribunal the link was certainly there and it could not agree with the Revenue that the assessee had not been able ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... and [1972] 86 ITR 724. Our High Court shares the view of the Punjab High Court in CIT v. Dinanath Dhawale (Misc. Civil Case No. 252 of 1970, decided on 4-4-1972). In that case, the ITO made an addition of Rs. 29,000 which was reduced in appeal to Rs. 19,000. In second appeal it was for the first time contended before the Income-tax Appellate Tribunal that the amount of. Rs. 19,000 was relatable to ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... made to s. 68 of the Act. This section provides that where any sum is found credited in the books of an assessee maintained for any previous year, and the assessee offers no explanation about the nature and source thereof or the explanation offered by him is not, in the opinion of the ITO, satisfactory, the sum so credited may be charged to income-tax as the income of the assessee of that previou ..... X X X X Extracts X X X X X X X X Extracts X X X X
|