Held, allowing  the Tribunal held that the assessee had declared the additional investments found as business income received by it in the normal course of business. Further, the quantum and basis of the amount surrendered had duly been stated by the assessee in its statement recorded during survey and as declared in the return of income. This had been accepted as it is, since the Assessing Officer nowhere denied or controverted these facts in the assessment order. The assessee had discharged its obligation to prove the source of investments declared by him, and the onus shifted to the Department to disapprove it. The income which was offered to tax stood credited in the profit and loss account of the assessee for the year. The Assessing Officer simply mentioned that the submissions of the assessee were not found acceptable as no cogent reasons supported by documentary evidence were being cited by him during survey. In case, the investment was to be treated as unexplained, the Assessing Officer had to bring on record some conclusive evidence or convincing finding as how the investment was being treated as unexplained. In the circumstances, it was a bald allegation of the Assessing Officer to consider the income declared as an unexplained investment.  As regards  the difference in stocks found by the authorities had no independent identity and was part and parcel of the entire stocks. Therefore, it could not be said that there was an undisclosed asset which existed independently and so as to treat the receipts not declared to the Department as receipt from business. he assessee had been confronted with not just the discrepancies found during the course of survey but the nature and source thereof and it clearly emerged that the source of such income was from his business operations. The income of Rs. 1 crore surrendered during the course of survey could not be brought to tax under the deeming provisions of sections 69 and 69A of the Act and had been rightly offered to tax under the head Business income.(AY. 2019-20)