P.G. Agarwal J.

1. Heard Mr. D.K. Mishra, learned senior advocate appearing for the appellant, and Mr. U. Bhuyan, learned Counsel for the Income Tax Department.

2. This is an appeal under Section 260A of the Income Tax Act, 1961, directed against the order dated March 15, 2002, passed by the Income Tax Appellate Tribunal, Guwahati, in I.T.A. No. 476(Gau) of 1993.

3. For the assessment year 1989-90, the assessee Mohanlal Sethi of Paona Bazar, Imphal (since deceased and at present represented by a legal heir Pramod Kumar Sethi), filed a return before the Income Tax Officer showing the total income of Rs. 69,408. The assessee had also shown investment in land and building amounting to Rs. 12,18,750. The assessee disclosed certain amounts as loan from family members and relations and the assessing authority holding, inter alia, that out of the said loan a sum of Rs. 8,35,000 on account of loan is not genuine and accordingly it was added as income of the assessee.

4. The said assessment order was challenged before the Commissioner of Income Tax in Appeal No. Imp-14/91-92 and the appellate authority allowed the appeal and directed deletion of the said amount.

5. Feeling aggrieved, the