1993 (12) TMI 30

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....s filed under section 256(2) of the Income-tax Act, 1961, one at the instance of the Revenue and the other by the assessee. Both these applications pertain to the assessment year 1984-85 and are directed against a common order passed by the Income-tax Appellate Tribunal. We have heard learned counsel for the parties. The assessee is a registered firm engaged in the business of purchase and sale....

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....luded by findings of fact. Where the additions were maintained by the Tribunal, it found that although the identity of the depositors has been established, their capacity to make the deposits was not established because, firstly, there was no evidence about the activities as claimed by the depositors, secondly, from the alleged activities, there could hardly be any savings out of which the deposit....