Separate additions for suppressed profits and unexplained cash credits are sustainable when they arise from distinct income sources.

Separate additions were permissible where estimated business profits were taken from the disclosed business on account of under-reporting, while unexplained cash credits were treated as income from an independent undisclosed source. A combined addition was impermissible only if both sums arose from the same business source, which was not shown here. The objection to double taxation also failed because the point was not properly raised before the Tribunal, and a question of law cannot arise for reference on a point not so raised. The reference therefore failed and the Revenue's position was upheld.

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Issues: Whether an estimated addition for suppressed business profits and a separate addition for unexplained cash credits could both be sustained when they were treated as arising from distinct sources, and whether the objection that both additions amounted to double taxation gave rise to a referable question of law.

Analysis: The additions were held to fall under two different heads. The estimate of gross profits was made on the footing of under-reported business results from the disclosed business, while the cash credits were treated as income from an undisclosed source, possibly outside the books. A combined addition is impermissible only where both sums are attributable to the same business and the same source of income. The objection was also not shown to have been raised before the Tribunal in the form now advanced, and a question of law cannot be said to arise from the Tribunal's order unless that point was actually raised before it.

Conclusion: Both additions were legally sustainable as distinct items of income, and the reference failed because the point was not properly raised before the Tribunal. The answer was against the assessee and in favour of the Revenue.

Ratio Decidendi: Separate additions are permissible where one is based on estimated business profits from a known source and the other on unexplained cash credits treated as income from an independent undisclosed source; a question not raised before the Tribunal does not arise for reference under section 66(1) of the Indian Income-tax Act.

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