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TMI Blog1981 (1) TMI 84X X X X Extracts X X X X X X X X Extracts X X X X ..... ginally from Bhavnagar District. The ITO found that there were following cash credits in the books of the assessee: (i) Rs. 25,500 Keshavlal Mulji (ii) Rs. 22,000 Dharmeshi Premji (iii) Rs. 25,000 Bhavan Odhavji . Rs. 72,500 . 2. For reasons stated the ITO held that these cash credits were not established and added total of this Rs. 72,500 in the total income of the assessee. 3. Th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Cal). Shri Harne stated that the Department would be justified in relating the cash credits as unexplained investments. 5. Shri K.C. Patel the ld. counsel for the assessee pointed out that the credits were agriculturists and were persons of fairly good means. Their land holdings were fairly substantial. They had also irrigation facilities. None of them was a closed relation of the assessee thoug ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rson and that person has accepted the transaction, the burden shifts on the Revenue. The Revenue can certainly show the so called creditors were not persons of adequate means in relation to the amount involved; the Revenue can also show that such transaction in fact did not take place. In this very case however, Revenue has not shown any of these two. If according to the Revenue these parties, had ..... X X X X Extracts X X X X X X X X Extracts X X X X
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