COMMISSIONER OF INCOME TAX Vs. GAJANAN CHAMPALAL BAJAJ

JUDGEMENT

(1.) Heard Mr. Anand Parchure,learnedCounselfor the applicant and Mr. K. P. Devani, learned Counsel for the respondent.

(2.) These two reference applications under Section 256(2) of the Income Tax Act, 1961 are filed by the Revenue against the order of the Tribunal dated 02/11/1993 in R. A. Nos. 392 and 393/Nag/93 declining to refer the following questions of law for the opinion of this Court:

(3.) The assessment years involved herein are 1985-86 and 1986-87. On 28/10/1985 the premises of the assessee was searched wherein books of account of the assessee and its group concerns were seized. During the course of search it was found that the assessee had invested amount by way of bank deposits and National Savings Certificates. The assessee contended that the amounts invested were belonging to the individual and not to the assessee- HUF. However, the Assessing Officer passed assessment order making additions on account of interest in investments and also unexplained investment in silver under Section 69-A of the Act.