1. These two appeals arise out of the orders passed in respect of two assessment years 1983-84 and 1984-85. The question involved in both these appeals is one and the same and therefore, they are taken up for consideration together and disposed of by this common order.

2. The assessee is a Registered Firm of construction Engineers and Designers. On 29.9.1984, assessee filed a return admitting an income of Rs.4,00,000/-. On 30.1.1985 the assessee again filed a return disclosing an income of Rs.3,95,430/-. Another revised return was filed on 3.9.1986. In the interregnum between the filing of the return on 30.1.1985 and 3.9.1986, a search under section 132 was conducted in the assessee’s premises on 29.7.1986. The assessee’s main income during the year is from the contract receipts for civil construction from M/s. Karnataka Ball Bearings Corporation Ltd. The material on record disclose that the assessee submitted a tender for Rs.1,28,18,413/- dated 29.3.1982 for civil work for the aforesaid company to their architects Master and Associates, Bangalore. On 16.7.1982, the assessee was intimated about the allotment of the work. According to the assessee the work commenced in Au