Unexplained income addition sustained where family funds were inferred from land purchases in sons' names without proof of independent source.

Where land was purchased in the names of the sons of a Hindu undivided family, affidavits asserting their individual ownership and solvency were insufficient because they did not clearly show an independent source of purchase funds. In the absence of acceptable proof of separate financing, the surrounding facts justified the inference that the consideration came from family funds, making the addition as unexplained income reasonable. The analysis thus supports treating the purchase money as income from undisclosed sources when the alleged independent source is not established by credible material.

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Issues: Whether the Tribunal was justified in sustaining the addition of Rs. 53,500 as income from undisclosed sources on the footing that the purchase money for land standing in the names of the assessee's sons was not spent by them in their individual capacity.

Analysis: The land was purchased in the names of the sons of the Hindu undivided family. The assessee relied on affidavits asserting individual ownership and solvency of the sons. The affidavits did not furnish clear and acceptable material showing the independent source of funds for the purchase. The source of the money was a within the knowledge of the family members, and the absence of disclosure or proof of an independent source justified the inference that the consideration came from family funds. On those facts, the addition as unexplained income could not be said to be unreasonable.

Conclusion: The question was answered in the affirmative, against the assessee. The addition of Rs. 53,500 as income from undisclosed sources was upheld.

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