TMI Blog1994 (9) TMI 54X X X X Extracts X X X X X X X X Extracts X X X X ..... ,040 making an addition of Rs. 9,79,829 as income from other sources besides unexplained investment in the purchase of a car of Rs. 70,000 and subscription to a chitty of Rs. 10,281. The assessee disputed this addition in appeal before the Commissioner of Income-tax who allowed it in part, deleting an amount of Rs. 1,46,497 out of the income added under the head "Other sources", but sustaining the assessment in other respects. On further appeal to the Tribunal by the assessee, the Tribunal while sustaining the additions relating to the investments on the car and the chitty, deleted the entirety of the addition made under the head "Other sources". The Revenue has filed Original Petition No. 6628 of 1991 against the deletion under the head " ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he total addition of Rs. 9,79,829 made under the head "Other sources". That finding was accepted by the Department and was not challenged in appeal before the Tribunal. The finding of the Commissioner was that that amount had been deposited in the Mylapore branch of the Punjab National Bank in the joint names of the assessee and her father, but the amount belonged to the father. This was taken as a circumstance to indicate that Bharathan, the father, had been depositing money in the name of the assessee in various accounts. The Tribunal noted that the assessee did not have the use of the money deposited in her name in the Quilon branch of the Federal Bank. That account which was opened on March 30, 1983, was actually closed on March 2, 1984 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... o the assessee's father and not herself. But we are not in a position to agree with counsel on this submission. The Tribunal has discussed this question very elaborately from paragraph 18 onwards. We do not find that the alleged non-filing of the appeal by DKB and Co. has influenced the Tribunal in its decision that the amount belonged to Bharathan and not to the assessee. Even otherwise, it was pointed out by counsel for the assessee before us that the Tribunal had in its order in Income-tax Appeals Nos. 992 of 1986 and 858 of 1988 relating to the assessment of DKB and Co., for the year 1983-84, affirmed the assessment made on that firm on the amount of Rs. 41 lakhs offered by it for assessment. Counsel also referred to the assessment made ..... X X X X Extracts X X X X X X X X Extracts X X X X
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