R. Gururajan, J.—These references are at the instance of the Revenue as well as at the instance of the assessee. The facts and law involved in all these references are interrelated and hence we have heard all the three references together. A common order is passed in this order disposing of all these three references. The two references at the instance of the Revenue are I. T. R. C. Nos. 39 and 40 of 1996.

Facts in I. T. R, C. No. 39 of 1996 :

2. This reference relates to the assessment in the case of P. R. Metrani, a Hindu undivided family (for short "the HUF") for the assessment year 1981-82. The assessment was initially concluded on September 17, 1984, in terms of Section 143(3) read with Section 144B of the Income Tax Act, 1961 (for short "the Act). The controversy relates to an income assessed for a sum of Rs. 19,95,117. A search was conducted by the Department in the residential premises of Metrani, viz., Ranganatha Nilaya, and during the search, documents were seized and based on the search documents two items were added, viz., Rs. 7,26,810 and Rs. 12,68,307, totalling to Rs. 19,95,117 as earned in business for the assessment year 1981-82. The assessing authority in th