Dismissing the appeal of the Revenue the Court held that  the Tribunal rightly concluded that the protective assessment was not warranted in the hands of the assessee because the assessee has been able to discharge the onus for showing the nature and source of credit entries in the bank account of Kalo Engineering works ( KEW), Pragati Engineering Company (  PEL)  as well as, in the bank accounts of  N.C.Jain (NC)and P.L.Mittal (PL))  which in turn are sourced from SW and its subsidiaries-Tribunal after verifying and examining the factual position has granted relief to the assessee and the Revenue has failed to make out a case to set aside the order passed by the Tribunal. (BP. 1-4 1986 to 27 th August 1996)