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5.3. Be it as it may, I now consider the additions made in each of the year under appeal, separately on merits.

Assessment Year 2003-04

6. The only ground taken by the assessee is against the addition of Rs.1,50,000/- being investment in KVP, which is in the name of Smt. Kajal Ghosh, wife of the assessee.

6.1. The total investments in the name of Smt. Kajal Ghosh in KVP was Rs.3,40,000/-. The assessment of Smt. Kajal Ghosh was re-opened u/s 148 of the Act and this amount was added has her income in the assessment order dt. 29/12/2012. It was part of the larger addition made towards undisclosed investments. Before the Assessing Officer, Smt. Kajal Ghosh, explained that the investment of Rs.1,50.000/- was made by her from out of withdrawals from her PF Account. The Assessing Officer rejected this explanation as the ground given for withdrawals of PF was education of child.

8.1.1. Regarding the other two amounts, being interest on KVP of Rs.9,250/-, and NSC of Rs.2040/-, admittedly the KVP and NSC are belonging to the assessee. The assessee claims that these receipts were seized and no interest was realized by him till date and hence he could offer the same to tax on receipt basis.

I am of the considered opinion that this addition is rightly made by the Assessing Officer and sustained by the ld. CIT(A) as interest has accrued to the assessee on these two investments, which admittedly belonged to the assessee. The claim of the assessee that it is following receipt basis and hence cannot be taxed during the current year, is not accepted for the reason that, no method of accounting is followed by the assessee, who is only a salaried employee. Hence, we set aside this issue to the file of the Assessing Officer to calculate the interest accrued during this year only and bring it to tax. In the result, this ground of the assessee is allowed in part.

17. Ground No. 1, is on the legal issue, as to whether the AO has discharged the burden of proof that lay on him while holding that the assessee's wife, minor & major sons, mother-in-law, father-in-law, are benamidars of the assessee.

17.1. Consistent with the view taken by me while disposing of the appeal for the assessment year 2003-04, I adjudicate this issue in favour of the assessee.

18. Ground No. 2 is on the addition of Rs.44,936/-, being interest on KVP, NSC and SB Account. The facts are identical to Ground No. 2 for the Assessment Year 2004-05. Consistent with the view taken by me therein, I hold that interest of Rs. 11,850/-on KVP and interest income of Rs.1,609/-, on the bank account in the name of Smt. Kajal Ghosh, cannot be added in the hands of the assessee. Hence the same is deleted. The other 2 amounts being interest on KVP of Rs.9,875/- & 13,004/-, and interest on NSC of Rs.2,615/- and MIS of Rs. 5,000/-, belonging to I.T.A. No. 579/Kol/2016 Assessment Year: 2003-04 I.T.A. No. 580/Kol/2016 Assessment Year: 2004-05 I.T.A. No. 581/Kol/2016 Assessment Year: 2005-06 I.T.A. No. 582/Kol/2016 Assessment Year: 2006-07 I.T.A. No. 583/Kol/2016 Assessment Year: 2007-08 Sri Sudipta Ghosh the assessee are rightly brought to tax in the hands of the assessee. Hence this ground of the assessee is allowed in part.

39. Ground No. 2 is on the issue of addition of Rs.70,492/-, being interest on KVP, NSC and SB account. The facts are identical to Ground No. 2 for the Assessment Years 2004-05, 2005-06 & 2006-07. Consistent with the view taken by me therein, I delete the interest of KVP and SB of Rs.18,900/- and Rs.2242/-. The other addition is not disputed. If this interest has been brought to tax in the earlier assessment years on the ground that the assessee has to be taxed on accrual basis, then no further interest can be brought to tax in this year as it would tantamount to double taxation. Hence this issue is set aside to the file of the Assessing Officer for fresh adjudication in accordance with law.