TMI Blog1993 (12) TMI 96X X X X Extracts X X X X X X X X Extracts X X X X ..... 0 3. Kum. T.J. Deepa (minor daughter) Rs. 33,750 The amounts represented amounts of investments in immovable properties. The ITO further noticed that the minor children had only fixed income and therefore, they could not have income from other sources. The funds for investments must have proceeded only from the assessee, who is their father. Though such sums were assessed under the amnesty scheme in the respective hands of the minor children, he would still hold that it was the assessee who financed the investments in the name of the minor children, in view of the limited sources of income for the minor children. The assessee did not succeed before the first appellate authority and hence he is on second appeal before the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 1984-85 51,940 lease rent, dividend, etc. T.J. Deepa (minor daughter) 1974-75 31,558 (admitted to benefits of partnership in Mavoor Trade Links A. Rajan Co. 1975-76 58,570 . 1976-77 15,847 . 1977-78 48,150 Beneficiary in Deepa Dhismaja Benefit Trust, which is a partner in firms Mavoor Trade Links A. Rajan Co. 1978-79 51,595 . 1979-80 35,690 . 1980-81 23,760 . 1981-82 44,350 lease rent, dividend, etc. 1982-83 69,600 . 1983-84 26,280 . 1984-85 48,020 . They were having accumulations over the years from ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... se of T.J. Deepa, total assessed income would come to Rs. 4,53,420. After exclusion of income offered under other sources in a sum of Rs. 33,750, it comes to Rs. 4,19,670. Further, it is seen that the minor children were beneficiaries in the trust, who were partners in Mavoor Trade Links, A. Rajan Co. They were also admitted to the benefits of partnership in Mavoor Trade Links, A. Rajan Co. and Kalpaka Service Station for some years and were also receiving income by way of lease of lorries to Kerala Transport Company. It is in such context, Shri Venkateswaran, learned Chartered Accountant, pleaded that the children had accumulation over the years. In order to verify this, we direct the ITO to take the total of the income assessed upto a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Assessing Officer in the impugned assessments will stand confirmed. Otherwise, it will stand deleted. For this limited purpose, the issue is restored. 5. The second issue in the assessee's appeal is against the addition of Rs. 27,410. In the wealth-tax return of minor Jaikish, the Assessing Officer noticed that the net wealth at the beginning of the year amounted to Rs. 3,35,496 without the value of ornaments and that at the close of the year without such ornaments amounted to Rs. 3,76,172. Thus, the increase in the wealth amounted to Rs. 40,676. Further the assessee had paid advance tax of Rs. 22,728. Hence, the minor child had to explain the increase in investment to the extent of Rs. 63,404. As against this the minor child had only Rs ..... X X X X Extracts X X X X X X X X Extracts X X X X
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