1982-83. The concealment with respect to the collection of refundable empty bottle deposits would never have come to light, but for the search operations conducted by the Revenue on 16.03.1985. In other words, the finding of the Tribunal is that there was a deliberate and wanton concealment on the part of the assessee, and this finding is not dislodged before us in any manner by the assessee. So far as the distinguishing aspect which is sought to be made by the learned counsel for the assessee referring to the fact that the Supreme Court in United Breweries case (2nd cited supra) had distinguished the judgment of the Punjab Distilling case (1st cited supra) is concerned, we may point out at once that the United Breweries case is in relation to the sales tax. Though the Supreme Court, while analyzing the facts of Punjab Distilling case had made a mention that the decision of the case is on its peculiar facts, the crucial aspect of the ratio laid down in that case is to the effect that the amount collected on account of the refundable empty bottle deposit is a trading receipt and is required to be brought into the profit and loss account. It is not the contention of the learned counsel for the assessee that the amount received on account of refundable empty bottle deposit is not a trading receipt. As a matter of fact, the assessee himself for the assessment years 1981-82 and 1983-84 treated the same as trading receipt. In that view of the matter, the distinguishing aspect which is sought to be made, has no distinction at all. Further, in the absence of dislodging the finding of the Tribunal to the effect that there was a deliberate
