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1979 Supreme(All) 323

SATISH CHANDRA, K. C. AGRAWAL, R. R. RASTOGI
Pioneer Trading Syndicate – Appellant
Versus
Commissioner of Income-Tax – Respondent


Advocates Appeared:
S.B.L. Srivastava, R.K. Gaulati, Ashok Gupta

Judgment

Satish Chandra, C.J.

1. MESSRS. Pioneer Trading Syndicate, the assessee, carried on business in sports goods and also in radio and allied things. For the assessment year 1967-68, the ITO found in the assessee's books the following credit entries :

2. THE assessee had purchased a motor car for Rs. 14,500. According to him, the source of this money was two other deposits credited in the assessee's books, namely, of Rs. 10,000 by Sri Jagat Ram and of Rs. 14,500 by Smt. Viranwali. Sri Jagat Ram is the father and Smt. Viranwali, the mother of the assessee. THE ITO found that the explanation in respect of these credit entries was not satisfactory. He added all these credits amounting to Rs. 43,100 as the assessee's income from undisclosed sources. The assessee went up in appeal. The AAC reduced the addition by Rs. 3,000 in respect of the credit entries in favour of Sri Jagat Ram. The addition of the balance was upheld. The assessee then went up to the Tribunal in appeal. On behalf of the assessee, it was reiterated before the Tribunal that all the three creditors had made disclosures before the CIT under the Finance (No. 2) Act, 1965, of the following amounts :

3. THESE disclosures























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