1981 (6) TMI 98

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..... proprietor of a medical shop in the name of Vani's Pharmacy at Chidambaram. He owns 8.51 acres of wet lands in Chidambaram area, 3.32 acres of wet lands in Usupur Village and 51 cents of dry land in the same village. He maintains accounts for the medical shop as well as for the income and expenditure from the agricultural operations. The capital account contains details of the outlay on agricultur .....

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..... it is claimed that the income disclosed is abnormal in relation to the holdings. The ld. representative for the assessee, in reply, contended that the addition made for asst. yr. 1975-76 as confirmed by the AAC was only Rs. 3,413 out of Rs. 43,143. For asst. yr. 1976-77 the income of Rs. 31,120 was accepted by the ITO himself. It was contended that the assessee was doing cultivation by adopting th .....

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..... Rs. 18,000 to Rs. 40,000 in the course of six consecutive years, including the year under consideration as per statement filed by the assessee. Hence, it is not as though that the income of about Rs. 38,000 is shown regularly for each year. The crop of one year may be sold in another and there are also seasonal factors, number of crops, the nature of the crops and the yield. There is no positive .....

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