1 IN THE HIGH COURT OF JUDICATURE FOR RAJASTHAN AT JODHPUR -------------------------------------------------------- (1) INCOME TAX APPEAL No. 20 of 2008 COMMOF I.T. UDAIPUR V/S SHRI SATYENDRA KR DOSHI (2) INCOME TAX APPEAL No. 02801 of 2007 COMM OF I.T.,UDAIPUR V/S SHRI NAGENDRA KR. DOSHI BANSWARA (3) INCOME TAX APPEAL No. 21 of 2008 COMM OF I.T. UDAIPUR V/S VIRENDRA KUMAR DOSHI BANSWARA Mr. KK BISSA, for the appellant / petitioner Date of Order : 10.3.2008 HON'BLE SHRI N P GUPTA,J. HON'BLE SHRI DEO NARAYAN THANVI,J. ORDER ----- All these three appeals arise out of the same judgment of the learned Tribunal. The defects pointed out by the office in appeal no.02801/2007 are ignored. The search was conducted at the premises and consequent upon the search, returns were filed, and assessment proceedings were undertaken. During search, Rs.91 lacs' capital was found. The assessees are carrying on the business of money-lending since the time of their 2 father, for which money lending licence in the name of their father is available on record, which was renewed in the name of sons after death of father. The rate of interest that was being charged by the assessee and their father has also come on record, and the learned Tribunal below has arrived at the opening capital as on the date of commencement of the block period being 1.4.86 by making reverse calculations for the entire period. In our view, the calculations made are pure questions of fact, and do not involve any question of law. That being the only controversy involved, we do not find any force in these appeals. The same are, therefore, dismissed. ( DEO NARAYAN THANVI ),J. ( N P GUPTA ),J. /tarun/