This is appeal by Revenue against order of CIT(A), dt. 21st Dec., 2001 pertaining to asst. yr. 1998-99. grounds of appeal preferred by Revenue are as follows: "On facts and circumstances of case: (i) CIT(A) has erred in law in deleting entire addition made to trading account without showing as to how AO was not justified in making addition of Rs. 7,37,750. (ii) CIT(A) has erred in law in deleting addition of Rs. 2,09,37,000 made on account of unexplained public deposit accepted under s. 68 of Companies Act, especially when assessee had failed to file corroborative evidence despite of specific requirements as per IT Act, 1961. (iii) CIT(A) has erred in law in allowing relief of Rs. 10,52,231 disallowed by AO out of foreign travelling expenses without giving any reason whatsoever and without even discussing AO s order in his order. (iv) CIT(A) has erred in law in giving relief of Rs. 6,64,500 disallowed by AO out of entertainment expenses ignoring real factual proposition that in absence of evidence possibility of non-business purposes could not be absolutely ruled out." facts in relation to first ground are that assessee company is engaged in manufacturing of auto components. It filed return of income declaring income of Rs. 1,61,62,044, which was accompanied by audited balance sheet and manufacturing and trading account along with necessary annexures, etc. AO noticed that although total turnover of assessee had increased during year, however, there was nominal decline of 0.13 per cent in GP ratio as compared to preceding year. After considering explanation of assessee for such decline, AO made addition of Rs. 7,37,750 by increasing GP ratio by 0.13 per cent. In appeal, assessee assailed addition both on facts and in law. CIT(A) called for remand report from AO in this regard. After considering explanation of assessee as well as remand report of AO, CIT(A) in terms of his discussion in paras 12 to 12.2 has deleted addition. Revenue is in appeal against aforesaid addition. learned Departmental Representative has submitted that addition w s justified, inasmuch as, it was based on past results in case of assessee itself. learned Departmental Representative referred to order of AO to point out that leakage of revenue could not be ruled out since GP rate has declined this year. On other hand, learned counsel for respondent assessee has defended orders of CIT(A). learned counsel has pointed out that no specific defects were noticed by AO to conclude that there was leakage of revenue on account of marginal decline in GP rate. He has drawn our attention to paper book filed which, inter alia, contains submissions made before lower authorities in this regard. Our attention has been specifically invited to pp. 2 and 8 of paper book for demonstrating reason for decline in GP rate. We have considered rival submissions carefully. In our view, ground of Revenue is without any substance for reasons that marginal decline of 0.13 per cent in GP ratio cannot ipso facto be indicator that there is leakage of revenue. In instant case, assessee is company under Companies Act, 1956 whose accounts are statutorily audited and there are no adverse observations in this regard. In fact, reasons explained for marginal decline are also reasonable and can be accepted. AO has reproduced reply of assessee made before him wherein reasons for decline have been explained. Ostensibly, assessee explained that average selling price of one of its products, namely, connecting rods declined in this year. Further, purchase price of raw material remained same. None of these explanations has been commented adversely by AO and yet addition has been made. Under such circumstances, we are inclined to affirm conclusions drawn by CIT(A) that impugned addition was unwarranted. Accordingly, on first ground, Revenue fails. facts in relation to ground No. 2 are that assessee company had accepted public deposits from various persons. amount of such deposits raised was Rs. 2.12 crores. On being asked to justify source of such deposits, assessee submitted to AO that deposits were raised from public in terms of s. 58A of Companies Act, 1956; that deposits were raised by way of advertisement to general public at large in terms of approval granted by respective authorities under Companies Act, 1956. assessee submitted list of deposit holders along with their addresses. assessee also submitted that deposits have since been repaid fully and also filed evidence for same. As illustrative instance, assessee filed deposit application forms in case of three depositors totalling to Rs. 2,63,000. AO after considering explanation of assessee held that assessee company had failed to prove identification, creditworthiness and genuineness of transaction and he has, therefore, treated sum of Rs. 2,09,37,000 (i.e., total of Rs. 2,12,00,000 minus Rs. 2,63,000 for which application forms were submitted by assessee) as income from undisclosed sources. In appeal, assessee reiterated submissions that number of depositors were 1,331; that entire deposits were raised in terms of scheme approved by RoC under provisions of Companies Act, 1956; that assessee was rated by independent credit rating agency CARE and, therefore, its public advertisement inviting public deposits received good response; that details submitted contain date of deposit, maturity date, amount of deposit, name and address of depositor and also evidence of repayment. It was, therefore, argued that addition made was unwarranted. CIT(A) has deleted addition on ground that repayment of deposits made through account payee cheques was evidenced by receipts issued by bankers and thus deposits stood explained. Against aforesaid, Revenue is in appeal before us. Before us, learned Departmental Representative drew our attention to discussion made by CIT(A) in its concluding para 13 on this issue and submitted that CIT(A) has passed non-speaking order in this behalf. It was, therefore, contended that such non-speaking order be set aside and order of AO be restored. It is further submitted that assessee had failed to discharge onus cast on it in terms of provisions of s. 68 of Act whereby onus is on assessee to justify and prove identity, creditworthiness and genuineness of credit found recorded in books of account. On other hand, learned counsel appearing on behalf of respondent assessee had defended order of CIT(A) in great detail. emphasis of argument of learned counsel has been that entire details along with requisite evidence were filed before lower authorities. Our attention was drawn to pp. 9 to 140 of paper book wherein is placed various material which was furnished before lower authorities in this regard, namely, details of depositors, copy of advertisement inviting deposits, details of claim o f public deposits, director s report, credit rating by CARE , etc. learned counsel also submitted that at pp. 142 to 303 are placed copies of bank advise entries by bankers of depositors evidencing their repayment. It was, therefore, contended that in face of aforesaid uncontroverted material, CIT(A) has deleted addition; that order of CIT(A) might be brief but certainly is not devoid of reasoning for deleting addition. On facts also, it was contended that material on record clearly indicates that assessee has been able to demonstrate that public deposits in question have been received genuinely. That in any case, assessee has submitted to AO that if he was not satisfied with evidence placed before him, it was open to AO to depute his official for obtaining further evidences, if required, and that assessee was prepared to bear expenses for conducting such exercise. For this, our attention has been drawn specifically to communication addressed to AO, dt. 28th Feb., 2001, which is placed in paper book at p. 2 onwards. We have considered rival submissions as also material on record to which our attention has been drawn during course of hearing. undisputed facts are that assessee is company incorporated under Companies Act, 1956. In terms of s. 58A of Companies Act, 1956, assessee, under scheme approved by RoC, invited deposits from public. copy of said scheme is placed at pp. 132 to 136 of paper book. deposit was to be made by way of prescribed application form, sample copy o f which is also placed at p. 135 of paper book. application form contains various details, viz., name of depositor, address, period of deposit, contains various details, viz., name of depositor, address, period of deposit, details and mode of payment, nomination details, status of applicant, income-tax particulars. etc. In terms of aforesaid scheme, assessee was found to have invited deposits from various depositors, almost over 1,300, amounting to Rs. 2,12,00,000. said amount was found as credit in books of account maintained by assessee. AO, by referring to provisions of s. 68 required assessee to prove nature and source of such deposits. assessee, as is evident from our discussion from earlier para, could not submit confirmation from each of creditors. Certainly, in our view, seeking confirmation from each and every individual creditor was not easy task. Nevertheless, it also cannot be disregarded that credits in question certainly fall within scope of provisions of s. 68 of Act. Sec. 68 of Act authorizes AO to verify nature and source of credits appearing in books of account of assessee and in case assessee does not furnish explanation or furnishes explanation which is not to satisfaction of AO, credits in question can be assessed as income in hands of assessee. parameters to explain nature and source of credit are regarding identity, creditworthiness of creditor and genuineness. However, abovesaid conventional parameters have to be applied keeping in mind peculiar circumstances of case. We may hasten to add here that what we are suggesting is not that onus is not on assessee to explain nature and source of deposits in question. We are only pointing out difference in approach in evaluating evidence, adduced by assessee in support of his explanation for nature and source of deposits in question, that is required under circumstances. Therefore, with this background, we may examine material, which assessee has relied upon in support of its stand before IT authorities. Firstly, it is to be kept in mind that deposits have been received by assessee in terms of scheme approved by authorities under statute under which assessee is incorporated, namely, Companies Act, 1956. assessee has complied with various guidelines, instructions, etc. in this regard and there is no adverse observation in this regard on record. Thus, bona fides of action of assessee in inviting public deposits cannot be doubted. Secondly, entire deposits have been received through normal banking channels. We find that details of depositors along with their addresses were very much before lower authorities. assessee submitted, as illustration, copies of three application forms whereby it had received deposits for Rs. 2,63,000 which have been accepted as explained. fact that AO was satisfied about nature and source of credit on basis of application forms in case of three creditors itself shows inconsistency in his approach. If according to him, vetting of application form was enough to discharge onus cast on assessee under s. 68 of Act, he ought not to have made any addition. It is starkly evident that if AO was satisfied that assessee had discharged onus cast under s. 68 on basis of application forms of three depositors, nothing prevented him from being satisfied with rest of deposits also. This is for reason that there is no denying fact that entire deposits in question have been received by assessee on basis of application forms submitted by depositors. Further, it is clear from assessee s communication to lower authorities that only three application forms were submitted merely to illustrate manner in which transaction has been carried out. Moreover, for none of deposits had AO taken any suo motu steps to make independent inquiries. This is in spite of fact that assessee made written requisition in this behalf. This approach of AO, in our view, gives away premediated effort to make addition. On this account itself, we are inclined not to sustain order of AO. Nevertheless, going further, we notice that in large number of cases repayment cheques issued by assessee have been furnished before IT authorities. These cheques which are placed at pp. 142 to 303 of paper book contain endorsement of bankers of depositors, which clearly evidence repayment. aforesaid piece of evidence clearly demonstrates identity of deposit holders. Now, insofar as quantum of individual deposit is concerned, we find that same ranges from Rs. 5,000 to Rs. 15,000 in overwhelming majority of cases. Considered in face of fact that deposits have been received in response to public advertisement, through normal banking channels, repayments are evidenced by bank and most importantly, absence of any adverse material with Revenue, we see no reason to treat deposits as unexplained. Therefore, considering overall gamut of facts and circumstances of issue, we are inclined to affirm conclusion of CIT(A) in deleting addition made by AO. plea of Revenue that order of CIT(A) is non-speaking, we d o not find any justifiable reasons to interfere on this count. We find that CIT(A), after getting submissions and material from assessee, sent same to AO and called for remand report. AO duly submitted his report. Even at this stage, it was open for AO to have conducted further inquiries. But, no such opportunity has been utilized. Nevertheless, CIT(A), after having considered rival submissions has made decision to delete addition. While it may show absence of detailed discussion on part of CIT(A) in concluding issue, nevertheless, CIT(A) has, in extenso referred to submissions of assessee as also remand report of AO in this regard. Therefore, merely because order of CIT(A) is brief, cannot be reason to interpret it as non-speaking order. In contrast, non-speaking order is to be understood as one, which shows lack of application of mind on part of authority writing order. Having noted manner in which CIT(A) has proceeded to examine rival claims, it cannot be said that there is absence of application of mind on his part. Therefore, grievance of Revenue on this count is misplaced. Accordingly, Revenue fails on this ground. facts relevant to third ground are as follows. AO noticed that assessee had incurred sum of Rs. 21,25,814 on foreign travelling undertaken mostly by its directors. assessee explained that purpose of visit was for exploring market for its products. AO disallowed 50 per cent of expenditure on estimation basis, not being satisfied with evidence produced by assessee. Hence, addition of Rs. 10,52,231. In appeal, it was contended that expenditure was incurred wholly and exclusively for business purposes; that it was always not possible to demonstrate tangible results of expenditure. learned CIT(A), keeping in view submissions of assessee and following past history wherein such additions were not sustained, has deleted entire addition. Before us, learned Departmental Representative has argued that CIT(A) has passed non-speaking order as is evident from para 14 thereof. On other hand, learned counsel appearing on behalf of respondent assessee has defended order of CIT(A) by referring to paper book wherein detailed written submissions are placed, which were furnished to lower authorities. Our attention has been drawn to pp. 3 to 6 of paper book as also pp. 330 and 331. We have considered rival submissions. Indeed, perusal of assessment order reveals that addition has been made on ad hoc basis. AO has noticed failure of assessee to produce concrete results of foreign visits so as to justify expenditure. approach of AO to ascertain as to whether visits have been resulted in earning of profit or not is entirely misplaced. In fact, CBDT in Circular No. 4, dt. 19th June, 1950 has opined that while considering admissibility of visits to foreign country, same should not be approached from point of view as to whether such visits result immediately in earning of profits or not. Therefore, premise with which AO proceeded on issue is misconceived. Moreover, we find that no specific instance of any non-business related expenditure has been pointed out by AO on this count. order of CIT(A), even if we agree with learned Departmental Representative that same is brief, yet it brings out reasons adopted by him for deleting addition. In any case, having regard to our observations above, we are inclined to affirm conclusion drawn by CIT(A), albeit on different ground. Thus, Revenue fails in this ground. facts relevant to ground No. 4 are that AO perused details of expenditure of Rs. 10.19 lacs claimed by assessee under head Entertainment expenditure . AO observes in order that sum of Rs. 5,64,500 was of unexplained nature and not incurred exclusively for business purposes. Hence, disallowance of Rs. 5,64,500. In appeal, assessee submitted that disallowance was made in ad hoc and arbitrary basis. CIT(A), after considering submissions of assessee has deleted addition on ground that it was made without any basis. Revenue is in appeal before us. Before us, stand of learned Departmental Representative is on basis of observations of AO made in assessment order. On other hand, learned counsel appearing for respondent assessee has referred to paper book pp. 318 to 324 regarding details of expenditure in question. He has also referred to p. 6 of paper book wherein is placed submission made to AO. It is further submitted that expenses were fully vouched and audited. We have considered rival submissions, and find that ground preferred by Revenue is lacking in substance, inasmuch as, CIT(A) has correctly concluded that addition has been made by AO without any basis. Evidently, AO has not pointed out any particular voucher or expenditure, which was unrelated to business of assessee. There is no instance noticed by AO, which showed that expenditure was incurred for personal purpose. Moreover, accounts of assessee, as noted by us earlier, are statutorily required to be audited and have been so done. There is also no adverse observation by auditors in this regard. disallowance, therefore, was made by AO on mere surmises and conjectures. Therefore, CIT(A) appropriately deleted addition. We hereby affirm order of CIT(A) and, therefore, Revenue fails on this ground. In result, appeal of Revenue is dismissed *** ASSISTANT COMMISSIONER OF INCOME TAX v. AMTEK AUTO LTD.