Unexplained investment in spouse's name treated as assessee's income; factual finding, no substantial question of law arose.

Investment placed in the wife's name was treated as the assessee's unexplained income because the evidence showed no independent source of funds for the wife, her explanation for the purchase was unproved, and the alleged support from her brother was not credible. The High Court treated that conclusion as a pure finding of fact drawn from appreciation of evidence and probabilities. It also stated that no substantial question of law arose under section 260A because the dispute did not involve a debatable legal issue, but only the factual inference that the purchase consideration had been provided by the assessee.

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Issues: Whether the investment made in the name of the assessee's wife could be treated as the assessee's undisclosed income and whether that conclusion gave rise to any substantial question of law.

Analysis: The Tribunal found, on the evidence, that the wife had no separate source of income, her explanation for the purchase was unproved, the alleged source through her brother was not credible, and the purchase consideration was in substance provided by the assessee. The High Court held that the conclusion that the investment standing in the wife's name represented the assessee's unexplained income was a pure finding of fact based on appreciation of evidence. It further held that the case did not satisfy the tests for a substantial question of law under section 260A, since the finding did not turn on a debatable legal issue but on the proved facts and probabilities of the case.

Conclusion: The investment in the wife's name was correctly treated as the assessee's undisclosed income, and no substantial question of law arose on that issue; the challenge failed on merits.

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