( 1 ) A notice under Section 226 (3) of the IT Act, 1961 (Act), issued by the Tax Recovery Officer, Delhi (TRO), has since been challenged by the petitioners/appellants herein. Initially this Court remitted the matter to the TRO, which had issued the said notice. The matter was adjudicated upon and the claim of the petitioners was rejected. Against this order the petitioners had moved the present writ petition since dismissed by the learned Single Judge. Out of the said order, the present appeal arises.

( 2 ) IT is contended on behalf of the appellants that the IT authority in a proceeding against the petitioners had held that the transaction between the petitioners and one Visisth Chay Vyapar Ltd. (hereinafter termed as "vcvl") was an ingenuine transaction and, therefore, disallowed the deduction of interest on borrowed capital and then directed addition of the amount under Section 68a (68) of the IT Act. The CIT (A) had affirmed the order of the AO and had held that the explanation was not satisfactory and despite opportunity being given, the petitioners did not avail of the same to satisfactorily prove their contention. On the other hand, VCVL had obtained a dec