Department filed an appeal against the order of the Tribunal wherein the Tribunal deleted the addition of Rs. 739.04 lacs stating that payment by the assessee of the amount of Rs. 739.04 lacs had not been established from the seized material and therefore no addition could be made on this account ignoring the fact that the assessee never provided the details of the transaction either during the course of assessment proceedings or thereafter and the assessee was in the exclusive knowledge. High Court dismissed the appeal being question of fact.