Assessee had 40 percent share in a multistoreyed complex to be built. Assessee entered into an agreement with one, VIPL whereby latter acquired right of such 40 percent share of assessee along with obligation to develop multistoried complex for a total consideration of Rs. 42 crores. Assessee contended that amount received by it was only a security deposit to check performance of VPIL and same was to be returned on completion of project. A search was carried out on ‘A’ Group of companies in which a ‘note’ was found and seized in which it was found that amount received by assessee was account of sale consideration. Assessing Officer included amount of Rs. 92 crores total income of assessee. The assessee contended that there was no such condition in agreement enabling VIPL to claim refund of any part of consideration. In course of recording of statement of directors of VIPL, it was categorically admitted that sale consideration paid to assessee was Rs. 42 crores. Further, VIPL showed entire sum of Rs. 42 crores as stock-in-trade thereby confirming interpretation that real intention was that entire sum was towards sale consideration and not to be treated as part of security deposit. Allowing the appeal of the revenue the Court held that; on facts, security deposit was a mere camouflage or a devise to postpone tax liability towards an uncertain date, at convenience of assessee, thus, Assessing Officer was justified in making impugned additions.