COMMISSIONER OF INCOME-TAX Vs. REKHA BAI

JUDGEMENT

(1.) We have heard the learned counsel for the parties and perused the impugned order dated Dec. 14, 20051, passed by the High Court of Judicature at Madras. The High Court has dismissed the appeal filed under Sec. 260A of the Income-tax Act, 1961 on the ground that no substantial question of law arises.

(2.) Learned counsel appearing for the appellant submitted that the full value of the pronotes seized at the time of survey should have been taken into account and there was no question of taking only 30 per cent, of the face value as the amount representing is disclosed income.

(3.) From the order of the first appellate authority, we find that the Assessing Officer had examined some of the borrowers mentioned in the pronotes and they have categorically stated that the amount advanced is 50 per cent, or less which explanation has been accepted by the first appellate authority and confirmed by the Tribunal.