In the result, appeals by the Revenue for the A
Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member
194C of the Act. The AO has not brought out that such payers were bogus or did not exist or that such receipts were not genuine. Thus, the sources of such receipts can be taken to be from contractual receipts. It is also noted that the appellant had not filed any returns in any of the previous years and specifically