S ARUNACHALA NADAR Vs. COMMISSIONER OF INCOME TAX

JUDGEMENT

(1.) THE questions similar to those referred to us at the instance of the assessee for the assessment years 1974-75 and 1975-76 were considered by this court for other assessment years and the questions were answered against the assessee and in favour of the Revenue, in the case of CIT v. K.S. Imam Saheb [1969) 71 ITR 742 (Mad). Even otherwise, questions Nos. 2 and 3 are purely questions of fact concerning the estimated income of the assessee in respect of the income from coconut thopes, coir and toddy businesses and from agriculture and do not raise any question of law. THE first question is one which is covered against the assessee. That question being as to whether the income from coconut thopes is not an agricultural income. THE earlier decision of this court is reported in CIT v. K.S. Imam Saheb [1969] 71 ITR 742. All the questions are answered against the assessee.