Double assessment of income does not erase the real recipient's tax liability or justify deletion of the addition.

Income found by the Tribunal to belong to an assessee-firm remains assessable in its hands even if the same amount has also been assessed in the hands of other persons. The Tribunal had recorded that the disputed amount arose from the firm's own accounts and was taxable as its income; that finding was decisive. Parallel assessment of the same income in another person's hands does not extinguish the real recipient's tax liability or justify deletion of the addition. The deletion was therefore not justified, and the issue was answered against the assessee and in favour of the Revenue.

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Issues: Whether the addition representing income found by the Tribunal to belong to the assessee-firm could be deleted merely because the same amount had also been assessed in the hands of other persons.

Analysis: The Tribunal had itself recorded that the disputed amount was income of the assessee-firm derived from its own accounts and was liable to assessment. The fact that other persons had also been assessed in respect of the same income did not extinguish the assessee-firm's liability. Assessment in the hands of another person does not absolve the real recipient or owner of the income from tax liability.

Conclusion: The deletion of the addition was not justified. The income remained assessable in the hands of the assessee-firm, and the question was answered against the assessee and in favour of the Revenue.

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