Held  that the Tribunal was not erroneous in adopting the finding arrived at in the assessment proceedings especially in the context of no material having been placed before the Assessing Officer to substantiate the sundry credits claimed. The mere disclosure of the name and addresses of the sundry creditors could not lead to substantiation of the credits especially when there was no evidence produced regarding the transactions which led to the credit. The mere acceptance of the entirety of the purchases in the appeal would not lead to substantiation of the credits claimed, since the purchases which led to the credit, had not been established before the Assessing Officer. There was no material available on record before the Assessing Officer, the Commissioner (Appeals) or the Tribunal, to take a contrary decision except to confirm the penalty levied under section 271(1)(c).