JUDGMENT

S. C. AGRAWAL, J. :—These appeals filed by the assessee against the order dated February 24, 1977 passed by the Income-tax Settlement Commission (hereinafter referred to as the Settlement Commission), related to assessment years 1971-72 and 1972-73. The appellant carries on business as a dealer in art pieces, antiques and curios at Bangalore. During the assessment year 1971-72 the appellant received a total amount of Rs. 3,11,831/- by way of race winnings in Jackpots and Treble events in races at Turf Clubs in Bangalore, Madras and Hyderabad. The said amount was shown by the appellant in the capital account in the books. The appellant filed a return on March 27, 1972 declaring an income of Rs. 27,829/-. The appellant also made a sworn statement on January 6, 1973 before the Income-tax Officer and on the basis of the said statement the Income-tax Officer made an assessment order dated March 27, 1974 wherein he held that the sum of Rs. 3,11,831/- is not winnings in races and he treated the said receipts as income from undisclosed sources and assessed the same as income from other sources. For the assessment year 1972-73 the appellant showed receipts of Rs. 93,500/- as race w