Tribunal jurisdiction under section 255(3) depends on Assessing Officer-computed income, and factual cash-credit findings stood undisturbed.

For Tribunal jurisdiction under section 255(3), the relevant threshold is the total income as computed by the Assessing Officer, not an enhanced figure adopted by the Commissioner (Appeals); an appellate enhancement does not alter the statutory basis for single-member jurisdiction. On cash credits, the Tribunal's reversal of the Commissioner (Appeals) was sustained because it rested on a categorical factual finding that the assessee was willing to produce the creditors and support the loan transactions, and no material was shown to dislodge that conclusion. The Revenue therefore failed on both questions, and the Tribunal's order in favour of the assessee was maintained.

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Issues: (i) Whether the jurisdiction of a single member of the Tribunal under section 255(3) depended on the total income as computed by the Assessing Officer or on the enhanced income determined by the Commissioner (Appeals); and (ii) whether the Tribunal was justified in reversing the Commissioner (Appeals)'s finding on cash credits under section 68.

Issue (i): Whether the jurisdiction of a single member of the Tribunal under section 255(3) depended on the total income as computed by the Assessing Officer or on the enhanced income determined by the Commissioner (Appeals).

Analysis: The expression used in section 255(3) is the total income as computed by the Assessing Officer. The definition of Assessing Officer could not be stretched to treat an order passed by the appellate authority as an order of the Assessing Officer. The plain language of the provision controlled the answer, and the enhanced figure adopted by the Commissioner (Appeals) did not alter the jurisdictional test.

Conclusion: The single member had jurisdiction because the relevant figure was the income computed by the Assessing Officer, and not the enhanced income determined in appeal.

Issue (ii): Whether the Tribunal was justified in reversing the Commissioner (Appeals)'s finding on cash credits under section 68.

Analysis: The Tribunal recorded a categorical finding that the assessee was willing to examine the creditors and support the loan transactions, whereas no record was produced to rebut that finding. In the absence of material to dislodge the Tribunal's factual conclusion, no illegality in its interference with the appellate finding was established.

Conclusion: The Tribunal was justified in reversing the Commissioner (Appeals)'s finding on the cash credits.

Final Conclusion: The Revenue failed on both questions of law, and the Tribunal's order in favour of the assessee was maintained.

Ratio Decidendi: For section 255(3), the jurisdictional limit for a single member is determined by the income as computed by the Assessing Officer, and an appellate enhancement does not change that statutory basis; a factual finding on cash credits will not be disturbed absent material to show illegality or perversity.

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