TMI Blog1999 (12) TMI 21X X X X Extracts X X X X X X X X Extracts X X X X ..... er passed by the Tribunal, Ahmedabad, on January 12, 1999, in Reference Application No. 664 (Ahd.) of 1998. The questions sought to be referred by the Revenue are as under : "1. Whether, the Appellate Tribunal is right in law and on facts in confirming the order passed by the Commissioner of Income-tax (Appeals) deleting the addition of Rs. 3,82,895 on account of unexplained investment in jewe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... le article is not recorded in the books of account, if any, maintained by him for any source of income, and the assessee offers no explanation about the nature and source of acquisition of the money, bullion, jewellery or other valuable article, or the explanation offered by him is not, in the opinion of the Assessing Officer, satisfactory, the money and the value of the bullion, jewellery or othe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ments. Except the piece of paper found in the brief case, there was no other material to indicate that there was undisclosed investment in acquiring the ornaments. The Tribunal after hearing the appeal recorded the finding that the Assessing Officer failed to appreciate the explanation submitted by the assessee and decided to make the addition upon conjectures and surmises without any evidence to ..... X X X X Extracts X X X X X X X X Extracts X X X X
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