Allowing the appeal of the revenue the Court held that The finding recorded by the Tribunal that the Assessing Officer had not made any independent enquiry was perverse. On the basis of meticulous appreciation of material available on record, the Assessing Officer had recorded the conclusions. The Tribunal had not dealt with the conclusions of the Assessing Officer and in a cryptic and cavalier manner had allowed the appeal preferred by the assessee. The Tribunal had also failed to appreciate that in fact, the burden was on the assessee to establish the genuineness of the transaction. The order of the Tribunal was liable to be quashed. Matter remanded to the Tribunal.( AY. 2007-08)