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TMI Blog1981 (1) TMI 86X X X X Extracts X X X X X X X X Extracts X X X X ..... ; Rs. 1974-75 27,340 1975-76 62,550 1976-77 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ; 7,500 1975-76 40,960 1976-77 41,285 4. Pursuance to the directions given by the Commissioner the ITO record ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... bsp; Rs. 1968-69 2,31,000 1969-70 1,38,000 1970-71 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sp; 314 1973-74 350 1974-75 355 5. The Commissioner (Appeals) found it difficult to accept that the assessee had developed his capability to such an extent that he was in a position to get a salary o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... cent was shown. 8. Shri J.P. Shah, the learned advocate for the assessee, strongly relied on the progress made and the achievements of M.L.G. in the first 2 years. Shri Kathuria, the learned authorised representative for the revenue, strongly relied on the fact that the managing director was just a boy who could not put all efforts and on the fact that there was loss in the third year. 9. No material was placed before us which would show that being a boy M.L.G. did not handle the business as effectively as was done by his father. Even if some deduction is to be made because M.L.G. did not have as much experience in business as his father had, it has to be remembered that the father of M.L.G. got the remuneration of Rs. 64,800 in the assessment year 1971-72 and Rs. 72,000 in the assessment year 1972-73 and received even much higher remuneration in the assessment years 1968-69 and 1969-70. Shri Kathuria relied on the fact that there was a big jump in the remuneration of M.L.G. in a very small spell. The remuneration of Rs. 1,000 up to 13-9-1973 was increased by Rs. 500 from 14-9-1973 and was further increased by Rs. 2,500 from 1-1-1974. In our view, this could not be the ground for ..... X X X X Extracts X X X X X X X X Extracts X X X X
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