Jawahar Lal Gupta, J. - (1.) THE assessee has filed this appeal under section 260A of the Income-tax Act, 1961. It maintains that in the circumstances of this case the additions made by the impugned orders are unsustainable. A few facts may be noticed.
(2.) THE appeal relates to the assessment year 1990-91. THE assessee' filed its return declaring an income of Rs. 84,630. THE Assessing Officer after examination of the evidence made the following additions : (1) THE claim of the assessee for Rs. 1,000 on account of expenses was disallowed. (2) An addition of Rs. 23,000 was made on account of income from undisclosed sources. (3) Another addition of Rs. 35,000 was made. 2. THE additions at serial Nos. 2 and 3 were made under Section 68 of the Act. Aggrieved by the order, the assessee filed an appeal. The Commissioner of Income-tax (Appeals) accepted the assessee's claim in respect of the expenses of Rs. 1,000. The remaining additions were confirmed. The assessee filed a second appeal before the Income-tax Appellate Tribunal. The Tribunal granted partial relief. Out of the amount of Rs. 23,000, the assessee's claim in respect of Rs. 15,000 was accepted. So far as the addition of Rs. 35,000 is concerned, the appeal was dismissed. Hence, this appeal.
(3.) MR. Mittal contends that the assessee had received loans from Smt. Gurdev Kaur and MR. Amarjit Singh. Smt. Gurdev Kaur had a land and was, thus, in a position to advance a loan of Rs. 23,000. Similarly, even Amarjit Singh had made the payment by cheque. In this situation, counsel submits, the action of the authorities in sustaining the additions cannot be upheld.;