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18. Shri Naresh Kumar, the learned senior Departmental Representative strongly supported the order of the AO. He submitted that during the course of search, a large number of deposits in various names were found and seized. The names of some popular persons, like Sachin Tendulkar, L.K. Advani, Ravi Shastri, Kapil Dev, etc. were used for the purchase of such fixed deposits. He produced some of the original FDRs for our perusal and submitted that the use of the same pen, ink, continuous numbers of fixed deposits and similar style of writing, proved that all these FDs were purchased at one point of time by one person. The opening forms of the FDs were incomplete and carried neither the statutory introduction nor the complete address of the depositors. He, thus, argued that all these FDs carrying fictitious names were not genuine. He further submitted that it may be relevant to note that a large number of such FDs, i.e., having incomplete address, no introduction, purchased in serial numbers in the names of different persons by one person, were owned by certain groups, like Sanghvi group. Jaju group and Kamat group. He, therefore, argued that in view of the decision of the TM in Overseas Chinese Cuisine vs. Asstt. CIT (1996) 55 TTJ (Bom) (TM) 304 : (1996) 56 ITD 67 (Bom) (TM), rest of such FDs are also to be held to be non-genuine. The learned senior Departmental Representative then read the provisions of Section 68 and argued that Section 68 does not grant exemption to any category of assessee and is applicable equally to all kinds to assessees. There is no discrimination between one kind of assessee and another, so far as Section 68 is concerned. Relying upon the decision of the Hon'ble Supreme Court in the case of A. Govindarajulu Mudaliar vs. CIT (1958) 34 ITR 807 (SC), the learned senior Departmental Representative stated that it is for the assessee to prove the sources and the nature of the receipts appearing in its books of account. The Department has to prove neither the source nor the nature of the receipts, as has been held by the Madhya Pradesh High Court in Seth Kalekhan Mohamed Hanif vs. CIT (1958) 34 ITR 669 (MP) which decision has been affirmed by the Hon'ble Supreme Court in Seth Kalekhan Mohd. Hanif vs. CIT (1963) 50 ITR 1 (SC). He submitted that the same principle has been reiterated by the Supreme Court in CIT vs. Devi Prasad Vishwa Nath Pd. (1969) 72 ITR 194 (SC), by Calcutta High Court in Shankar Industries Ltd. vs. CTT (1978) 114 ITR 689 (Cal), C. Kant & Co. vs. CIT (1980) 126 ITR 63 (Cal), Oriental Wire Industries (P) Ltd. vs. CIT (1981) 131 ITR 688 (Cal). He also placed reliance on the decision of the Calcutta High Court in Prakash Textiles Agency vs. CIT (1980) 121 ITR 809 (Cal) where the decisions of the same High Court in Basdeo Agarwalla vs. CIT (1980) 121 ITR 901 (Cal), Sri Ram Jhabarmal Ltd. vs. CIT (1967) 64 ITR 314 (Cal), Northern Bengal Jute Tdg. Co. Ltd. vs. CIT (1968) 70 ITR 407 (Cal), Dulichand Om Prakash vs. CIT (1978) 113 ITR 476 (Cal) & (1978) 114 ITR 689 (Cal) have been elaborately discussed. He submitted that in view of the above decisions, the entire burden is upon the assessee and the assessee has to prove the following :