(1.) We have heard Shri Rahul Agarwal, learned counsel appearing for the assessee-appellant. Shri Ashok Kumar appears for the Income-tax Department. This income-tax appeal filed under section 260A of the Income-tax Act, 1961, arises from an order of the Income-tax Appellate Tribunal, Agra Bench, Agra, dated March 26, 2013, for the assessment year 2006-07.
(2.) The appeal has been preferred the following substantial questions of law:
(3.) We have examined the orders of the Assessing Officer, the Commissioner of Income-tax (Appeals) and the Income-tax Appellate Tribunal and find that all the three authorities have not accepted the explanation of the assessee-appellant that two gold biscuits, which were recovered from the locker of the assessee, did not belong to him. The findings recorded by the Tribunal are quoted as below: