TMI Blog1996 (4) TMI 22X X X X Extracts X X X X X X X X Extracts X X X X ..... s an income-tax reference at the instance of the assessee and the following question of law has been referred by the Tribunal for answer by this court : "Whether the Appellate Tribunal, in the facts and circumstances of the case, was justified in treating a part of the income declared as agricultural income by the assessee-Hindu undivided family as its income from undisclosed sources ?" The br ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 0 in the accounting years 1978-79 and 1979-80, respectively, as the assessee's income from undisclosed sources. The assessee filed an appeal in which the additions were reduced to Rs. 15,000 for each of the two years. In appeal before the Tribunal, the assessee could not succeed. Hence, it moved an application before the Tribunal for making a reference to this court and accordingly the aforesaid ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sildar and other evidence placed by the assessee before the Tribunal. Learned counsel for the assessee contended before us that the finding recorded by the Income-tax Officer as well as by the appellate authority has no basis, the Department has not produced any evidence and, therefore, whatever facts have been brought on record by the assessee, should be accepted. We do not share the view of le ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... proximate estimate and no hard and fast rule can be made out on the questions of fact. Therefore, we are of the opinion that the assessment made by the assessing authority does not suffer from any infirmity. Learned counsel for the assessee invited our attention to the case of Parimisetti Seetharamamma v. CIT [1965] 57 ITR 532 (SC). In that case, the assessee's income was not found to be correct ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
