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TMI Blog1979 (4) TMI 89X X X X Extracts X X X X X X X X Extracts X X X X ..... e ITO found that during the year, the assessee purchased on 27th Aug., 1973 a bus bearing No. TNF 4779 at a cost of Rs. 1,00,006. In the explanation for the source of this purchase the assessee stated that the amounts for the purchase came out of the gross income of the assessee before depreciation relating to the asst. yrs. 1972-73 to 1974-75. The assessee had not maintained any books of accounts ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he amounts available with the assessee, as could be seen from the assessments made for the earlier years, was sufficient to account for the purchase of the bus. He has given a detailed statement showing the wealth position as on 31st March, 1974 and the earlier years, which was given to the ITO as well and pointed out that as against the total amount of Rs. 3,36,415 available with him, the outgoin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s conforms to the working given by the ITO. The purchase of the bus was made on 27th Aug., 1973. As against the above deficit worked out by the ITO the income for the asst. yr. 1974-75 upto the period 27th Aug., 1973 has to be considered. On a proportionate basis this should come to about Rs. 30,000. The ITO has not taken into account the gross receipts on the sale of the car and lorry, which woul ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... see makes a borrowing at high rate of interest, the cash available at home could be regarded as nil. The assessee is a bus operator. He already had a certain number of buses. He has to provide for the working expenses of these buses. When he makes further purchases of buses, it is not likely that he spends away all his cash resources and to that extent borrows from financiers. The more reasonable ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n estimate has to be made of the likely cash the assessee would have retained with himself with an idea to have continuity of his business. Having regard to the facts in amount of about Rs.23,000 to Rs. 25,000 could be regarded as the opening balance of cash with him in the computation made even by the ITO. If this is deducted, the amount to be added could be taken at a round figure of Rs. 50,000. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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