1987 (11) TMI 30

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....) of the Income-tax Act, 1961, by the assessee dealing in bullion, silver, silver ornaments, etc., praying that the Appellate Tribunal be directed to draw up a statement of case on as many as seven questions proposed in the said application and refer the same for the opinion of this court. We have heard learned counsel for the parties at some length and are of the opinion that no question of la....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....nrecorded parcels is a question of fact and from the findings on this question, no question of law arises. The next question relates to the cash credits appearing in, the books of the assessee-firm in the names of the two partners. The explanation of the assessee-firm that the credits were introduced by the partners was not accepted and the unexplained cash credits were taken to be the income o....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....s recorded on that question. Sri Gulati also submits that an application under section 254 had been made before the Tribunal stating that it had failed to elaborate all the arguments and the submissions made on behalf of the assessee. It is stated that the plea that the addition could have been made only in the assessments of the partners was raised before the Tribunal but the assessee omitted ....