Charity collections through sale bills cannot be taxed as income without proper factual enquiry into the receipts.

Collections made by an assessee through charity sale bills were not liable to be assessed as income where the tax authority made a bald addition without the factual enquiries required by the Court's earlier binding decision. The Court reiterated that the nature of such receipts must be properly investigated before they can be brought to tax, and an unsupported assumption is insufficient. On that footing, the disputed amount was held not assessable as income, in favour of the assessee.

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Issues: Whether collections made by the assessee on account of charity through sale bills were liable to be assessed as income.

Analysis: The collections were added by the Income-tax Officer without the necessary enquiries indicated in the earlier binding decision relied upon by the Court. The Court applied its prior view that such a bald addition, without proper factual investigation into the nature of the receipts, was not permissible.

Conclusion: The question was answered in the negative and the disputed amount was held not liable to be assessed as income, in favour of the assessee.

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