JUDGMENT

ARIJIT PASAYAT, C.J.
At the instance of the assessee, the following question has been referred by the Incometax Appellate Tribunal, Cochin Bench (in short "the Tribunal"), on consideration of an application under section 256(2) of the Income Tax Act, 1961 (in short "the Act"), for opinion:"Whether, on the facts and in the circumstances of the case, the findings of the Tribunal that the explanation offered by the assessee about the nature and source of the cash credits in the aggregate of Rs.1,71,500 or any portion of it is not satisfactory, is perverse, unreasonable, contrary to law and one which no reasonable person would have come to that conclusion?"The dispute relates to the assessment year 197778. In the books of account, certain credits were noticed by the Assessing Officer, totalling Rs.5,36,500, in relation to 15 persons. It was indicated in each case that the amount received from the concerned person related to rent and security deposit of fishing boat. The Assessing Officer,...