PRABHAT RANJAN SARKER Vs. INCOME TAX OFFICER

JUDGEMENT

(1.) The assessee had filed the appeal originally on 26th March, 1984. After several months of filing of the appeal, the assessee filed additional grounds of appeal vide petition dt. 21st Aug., 1984. These grounds are against the charge of interest under Ss. 139(8) and 217. It is mentioned in the petition that the additional grounds do not require investigation and hence these should be admitted for being considered.

(2.) We have considered this request of the assessee. It is also clear that these grounds do not arise out of the order of AAC. Moreover, these grounds would require investigation into facts. We do not agree with the assessee that these grounds do not require investigation into facts. The additional grounds of appeal filed, therefore, are not being admitted for consideration as these grounds were not raised in the original appeal filed, as these grounds do not arise out of the order of AAC; and as these grounds would require investigation into facts.

(3.) The main contention in this appeal is against the addition of a sum of Rs. 84,233 as income from undisclosed sources. The facts may be mentioned here in short. There was search in the residential premises of the assessee on 24th Oct., 1971. The residential premises of the assessee were at 176, Patliputra Colony, Patna. As a result of the raid and search the following amounts were recovered and seized :