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Section 254 of the Income-tax Act, 1961 - Appellate Tribunal - Orders of - Block assessment years 1987-88 to 1997-98 - Assessing Officer made certain additions as unexplained investments while making block assessment under section 158BC - On appeal, Tribunal upheld addition which represented peak investment made in liquor business - However, no separate addition was made on account of peak amount in bank accounts as same stood covered in peak amount computed as unexplained investment - Later, assessee filed an application under section 254(2) pointing out that while working out peak amount in bank accounts, amount on account of bank interest had also been taken into account - Tribunal rejected application on ground that addition was made on account of capital employed in liquor business and no separate addition had been made on account of peak credit in bank accounts - Whether Tribunal was right in holding that no case for rectification had been made out - Held, yes Salil Kapoor for the Appellant. JUDGMENT N.K. Sud, J. - The assessee had filed this appeal under section 260A of the Income-tax Act, 1961 (for short 'the Act'), against the order of the Income-tax Appellate Tribunal, Amritsar Bench, Amritsar (for short 'the Tribunal'), dated 11-2-2004, dismissing his application under section 254(2) of the Act for rectification of its order dated 31-5-1999, passed in IT(SS) Appeal No. 23(ASR) of 1997 relating to block assessment years 1987-88 to 1997-98. 2. While making the block assessment under section 158BC(c) of the Act, the Assessing Officer had made additions of Rs. 1,54,07,808 and Rs. 59,67,500 as unexplained investments on the basis of pages 192, 193 and 194 of the documents seized by the Department at the time of search on 11-9-1996. 3. On appeal by the assessee, the Tribunal vide order dated 31-5-1999, upheld the addition of Rs. 59,67,500 which represented the peak investment made in the liquor business. The Tribunal also got the peak amount in 21 undisclosed bank accounts calculated by counsel for the parties, which worked out to Rs. 52 lakhs. However, since the Tribunal had upheld the addition of the peak amount of Rs. 59,67,500 on account of investment…

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