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<h1>Court directs Tribunal to refer peak credit theory question in income tax case, justifies Rs. 59,000 addition from undisclosed sources.</h1> The High Court of Madhya Pradesh directed the Tribunal to refer a question of law regarding the benefit of peak credit theory to the court for its opinion ... Cash Credits, Reference The High Court of Madhya Pradesh directed the Tribunal to refer a question of law regarding the benefit of peak credit theory to the court for its opinion in an income tax case. The court found that the addition of Rs. 59,000 as income from undisclosed sources was justified based on the material on record. The application was partly allowed, and each party was directed to bear their own costs.