Allowing the appeal of the revenue the Court held that ; the Tribunal acted erroneously and in a perverse manner insofar as directing deletion of the addition not proved before the Assessing Officer; applying the rule of probability, which is alien to the Act. There is absolutely no proof offered with respect to the additions made. However, before the first appellate authority, the assessee had produced proof of four depositors and four agents for the year 1999-2000 and six depositors and four agents for the year 2001-02, the same shall be produced before the Assessing Officer, who shall consider its veracity and enter a finding on the same. The remand is confined to that aspect, and with respect to the other, the assessee would have to satisfy the tax due. The Income-tax appeals are allowed with the limited remand. (AY. 1999 – 2000 2001-02)