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2014 (3) TMI 152 - HC - Income TaxReversal of CIT(A)’s order - Proper explanation not made - Addition made u/s 68 of the Act – Unaccounted cash credit – Whether the assessee offer explanation for different amounts credited in his account – Held that:- The Tribunal had not committed any error so as to give rise to substantial question of law - Entire issue was based on facts - The tribunal on the basis of evidence came to the conclusion that explanation was not acceptable - Different creditors were agriculturists and odd amounts were deposited - There was no explanation for this phenomena - the CIT(Appeals) decided the issue in favour of the assessee without pointing out as to which additional evidence admitted by the tribunal and considered by him had clinched the issue in favour of the assessee – Thus, the CIT(Appeals) in essence shifted the burden of establishing such facts on the Revenue rather than on the assessee – the entire issue is based on appreciation of facts – thus, no question of law arises – Decided against Assessee.
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