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11. Learned AR of the assessee submitted that the original return has no bearing on the assessment once valid revised return has been filed. He submitted that the receipt does not constitute an income since it is a mere windfall gain and it does not have a definite source with regularity or a return for labour, skill or capital. In support of the proposition that revised return substitutes original return, learned AR has relied on the decisions of the Hon'ble Karnataka High Court in the case of CIT vs. Mangalore Chemicals and Fertilizers Ltd. (1991) 191 ITR 156 (Kar) and CCIT vs. Machine Tool Corporation of India Ltd. (1993) 201 ITR 101(Kar). He relied on the decision of the Hon'ble Supreme Court in the case of Parimisetti Seetharamamma vs. CIT (1965) (57 ITR 532)(SC) wherein it has been held that the Act does not provide that whatever is received by a person must be regarded as income liable to tax and in all cases in which a receipt is sought to be taxed as income, the burden lies upon the department to prove that it is within the taxing provision. He also relied on the decision of the Supreme Court in the case of Universal Radiators vs. CIT (1993) 201 ITR 800(SC) wherein it is held that if the assessee has received any sum by an extraordinary set of fortuitous circumstances, then such sum profit cannot be charged to tax.