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Issues: (i) Whether addition could be made on account of alleged undisclosed investment in five properties; (ii) whether separate addition was justified on account of cash found in lockers and at the assessee's premises as suppressed professional receipts.
Issue (i): Whether addition could be made on account of alleged undisclosed investment in five properties.
Analysis: The Revenue failed to establish that the assessee had made any undisclosed investment in the properties. The finding was that the Assessing Officer had no justification for making additions on this basis.
Conclusion: The addition on account of undisclosed investment in the house properties was not sustainable and stood deleted, in favour of the assessee.
Issue (ii): Whether separate addition was justified on account of cash found in lockers and at the assessee's premises as suppressed professional receipts.
Analysis: The cash found in the lockers and at the premises was treated as having come from professional receipts. Since those receipts had already been considered in the return filed in response to notice under section 158BC of the Income-tax Act, 1961, no separate addition was warranted.
Conclusion: The separate addition for suppressed professional receipts was not justified and stood deleted, in favour of the assessee.
Final Conclusion: No substantial question of law arose, and the Revenue's challenge failed.
Ratio Decidendi: Additions cannot be sustained where the Revenue fails to prove undisclosed investment or any basis for a separate addition when the source of cash is already accounted for in the block return.
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