1981 (2) TMI 98

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....t to this assessment year amounted to Rs. 66,100. It was claimed before the ITO that this capital was out of the assessed incomes of the earlier years from the asst. yr. 1965-66 to 1975-76. According to the assessee, the assessee owned 19 bighas of agricultural land from which the agricultural income was about Rs. 3,000 each year. His family consisted of five persons only including the two children whose expenses were met out of the agricultural income and, therefore, the entire assessed income from 1965-66 onwards was available which was saved and was part of the capital investment in the business. The ITO, however, estimated the initial capital at the commencement of the asst. yr. 1965-66 at Rs. 2,000, the assessee's expenses at Rs. 2,000....

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....ion to the agricultural income, was available for investment in the business. He also submitted that in order to earn an income of Rs. 5,000, which was offered for assessment and actually assessed for the asst. yr. 1965-66, the initial capital of Rs. 5,000 estimated by the AAC was too low. Summing up, Shri Gulati vehemently argued before us that the nature and source of the entire capital of Rs. 66,100 at the commencement of the year relevant to this assessment year was satisfactorily explained and the addition on account of unexplained capital at the commencement of the year made by the revenue authorities was not justified. 4. On the other hand, the ld. Deptl. Rep. Shri Bara, besides relying on the orders of the revenue authorities, su....