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Issues: Whether the assessee established a nexus between the voluntary disclosure of income for one assessment year and the investment found in the later assessment year so as to exclude the addition as undisclosed income.
Analysis: The only material relied on by the assessee was the certificate issued under section 8(2) of the Voluntary Disclosure of Income and Wealth Act, 1976, showing disclosure of income and payment of tax. That certificate did not, by itself, establish that the investment of Rs. 54,000 in the purchase of potatoes came out of the disclosed income. No further evidence was produced to connect the disclosed amount with the disputed investment. A finding recorded without evidentiary support, and without proof of the connecting link, cannot sustain the assessee's claim in reference proceedings.
Conclusion: The assessee failed to prove the required nexus, and the addition of Rs. 54,000 was rightly not deleted; the question is answered in favour of the Revenue and against the assessee.
Final Conclusion: The reference is answered by holding that the disputed investment was not shown to have been made out of the voluntary disclosure, while the second part of the referred question was not required to be decided.
Ratio Decidendi: A voluntary disclosure certificate does not, by itself, prove that a later undisclosed investment was sourced from the disclosed income unless a clear evidentiary nexus is established.
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