TMI Blog2007 (7) TMI 236X X X X Extracts X X X X X X X X Extracts X X X X ..... d - finding of the Tribunal, in our opinion, are pure findings of fact based on appreciation of evidence and material on record and therefore assessee appeal is allowed - 99 of 1999 - - - Dated:- 31-7-2007 - R. K. AGRAWAL and VIKRAM NATH JJ. R. K Upadhyay for the Commissioner. R. S. Agrawal for the assessee. JUDGMENT 1. The Income-tax Appellate Tribunal, Allahabad, has referre ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... onal evidence produced by the assessee in terms of its letter dated April 24, 1995?" 2. The reference relates to the assessment year 1990-91. 3. Briefly stated the facts which give rise to the appeal are as under: 4. The assessee-firm deals in purchase and sale of supari and kattha. A return of income was filed showing a total income of Rs. 16,430 on November 7, 1990, and the assessee ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... h ample opportunity was given to the assessee for about two years from February 18, 1991, to February 12, 1993, during which period the case was under hearing. Therefore, he treated these deposits as unexplained credits under section 68 of the Income-tax Act, made additions of Rs. 2,90,000, P.s. 50,000, Rs. 1,21,000 and Rs. 1,00,000 besides making other additions. 5. The assessee went in appea ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 8. From the order of the Tribunal we find that the Tribunal has accepted the explanation offered by the assessee regarding the amount deposited by various persons. The source and the genuineness of the deposits has also accepted. The finding of the Tribunal, in our opinion, are pure findings of fact based on appreciation of evidence and material on record and therefore, we are of the considered ..... X X X X Extracts X X X X X X X X Extracts X X X X
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