1982 (1) TMI 23

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....essee in this case is a lady belonging to the Nattukottai Chettiar community. For the assessment year 1967-68, she returned total income of Rs. 2,764 disclosing, among other items of income, interest on deposits. The assessment was completed under s. 144 of the I.T. Act, 1961. Subsequently, the assessment was reopened, and the total income was determined at Rs. 48,170. The difference between the figure as originally assessed and the figure at which the subsequent assessment was made for the same year represented what, according to the ITO, was income from certain unexplained investments of the assessee. The assessee appealed against this assessment. The AAC reduced the addition made by the ITO and sustained it to the extent of Rs. 20,400 as....

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....y her at interest at the rate of 3 per cent. per annum, and both the principal and interest had gathered muster during all these years subject to personal drawings every year from 1944 onwards. It was urged that even after allowing for personal drawings, there was balance of Rs. 82,230 which was available to her. Examining these representations regarding the availability of resources, the Tribunal recorded a finding that, to the extent of at least Rs. 58,750, there was no dispute that the assessee had sources of money available to her. Indeed, it was on this basis that in the appeal against the relevant assessment, the AAC had restricted the addition to Rs. 20,400 as against Rs. 43,463 added by the ITO. After referring to this feature in....