Assessee, a dealer and broker of old cars made bank deposits and had cash receipts. Assessee claimed deposits were advance payments, subject to refund if deal did not go through. Duty on assessee to prove. Failing which, AO treated 15% of cheque deposit as income. Tribunal accepted. Additional ground that assessment raised for limited scrutiny to verify cash deposit could not estimate income on cheque deposits. Ground allowed following National Thermal Power Co Ltd v CIT (1998) 229 ITR 383 (SC) however ground rejected on merit following Circular No. 20/2015, permitting AO to take up additional issue in limited scrutiny of less than Rs. 10 lakhs.  (AY.  2016-17)