7. After going through the orders of the learned Members as well as the orders of the lower authorities, I am of the view that no disallowance was required to be made for the reasons given hereafter. The question for consideration is whether on facts of the case, the disallowance was justified in view of the specific provisions of section 40A(2)(a) of the Act. It would be appropriate to reproduce the relevant portion of the said provision below:
In pursuance of the direction of this Court under Section 66(2), Indian Income-tax Act, 1922, in Miscellaneous Civil Case No. 143 of 1950, the Income-tax Appellate Tribunal, Bombay, has submitted the statement of case on the following question of law : “Whether on the material on record the Appellate Tribunal could reasonably come to a finding that the sum of Rs. 8,500 was an income undisclosed sources ?”
