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2008] 306 ITR 267 [2010] 189 TAXMAN 263 (PUNJ. & HAR.) HIGH COURT OF PUNJAB AND HARYANA Commissioner of Income-tax v. Ramneet Singh* SATISH KUMAR MITTAL AND RAKESH KUMAR GARG, JJ. IT APPEAL NO. 515 OF 2007â-  FEBRUARY 13, 2008 I. Section 68 of the Income-tax Act, 1961 - Cash credits - Assessment year 1997-98 - While framing assessment, Assessing Officer made addition on account of unexplained cash credits on ground that assessee had failed to produce alleged creditors - On appeal, Commissioner (Appeals) deleted said additions observing that documents relating to loans had been produced by assessee before Assessing Officer during rectification proceedings, but same were not considered on ground that there was no mistake apparent on record - On revenue's appeal, Tribunal upheld order of Commissioner (Appeals) observing that creditors had been produced and their statements had been recorded wherein they had confirmed having advanced loans to assessee - Whether any substantial question of law did arise out of order of Tribunal - Held, no II. Section 69 of the Income-tax Act, 1961 - Unexplained investments - Assessment year 1997-98 - Assessing Officer made addition on account of unexplained investment in purchase of bus - On appeal, Commissioner (Appeals) deleted addition observing that Assessing Officer had estimated value of vehicle at higher amount as against that shown by assessee without there being any basis to arrive at such conclusion - Tribunal upheld order of Commissioner (Appeals) - Whether Tribunal had taken correct view - Held, yes III. Section 68 of the Income-tax Act, 1961 - Cash credits - Assessment year 1997-98 - Whether where assessee had produced sufficient documents to show that loan shown in name of two companies had been received from those parties, addition made by Assessing Officer on account of unexplained loans was rightly deleted by Tribunal - Held, yes Yogesh Putney for the Appellant. JUDGMENT Satish Kumar Mittal, J. - The instant appeal filed by the revenue under section 260A of the Income-tax Act, 1961 (hereinafter referred to as "the Act"), is directed against the order dated November 3, 2006, passed by the Income-tax…

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