1980 (10) TMI 85

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.... the proportionate amount and not the entire amount of interest was includible under s. 64 (vi) in the assessment of the assessee. 2. That the order of the AAC being erroneous on law and on facts may be set aside and the order of the ITO may be restored. 2. In order to better appreciate the rival submissions of the parties, it would be necessary to reproduce the order of the AAC under appeal....

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....-76 show that the amount of Rs. 2,500 gifted to them each by Smt. Bhagwati Devi, the appellant was credited in the books of M/s Chhedi Lal Kasera. In asst. yr. 1976-77, these amounts were carried forward in their capital accounts as opening balance. Smt. Saroj Devi received further gifts as Rs. 1,001 and Rs. 5,000 from Shri Shital Prasad and Smt. Bhagwati Devi. Smt. Chandrawati Devi received furth....

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....The remaining addition should be made in the hands of Shri Shital Prasad, father-in-law of these two ladies who has also made gifts to them and in whose case also provisions of s. 64 (vi) are applicable. The ITO should revise the assessment accordingly. 3. The ld. Rep. for the Dept. submitted that since Smt. Chandrawati Devi and Smt. Saroj Devi became partners of M/s Chhedi Lal Kasera with help....