Spouse's unexplained property and interest income may be taxed in the assessee's hands when ownership and funding lack supporting material.

Where a spouse's name is used for alleged ownership or investment, but the record does not show that the spouse received the funds for purchase, construction, or rental receipts, the resulting income may be treated as the assessee's own income. On the facts noted, there was no material to support the wife's independent source of investment or receipt of rent, so the house property income and the related interest income were included in the assessee's income and the reference was decided for the Revenue.

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Issues: Whether the income from house property and the interest income standing in the name of the assessee's wife were liable to be included in the assessee's income.

Analysis: The finding recorded was that there was no material to show that the wife had received the amount said to have been invested in the purchase of the plot or in the construction of the house. There was also no material to show that the wife had received rent from the house. On these findings, the house property and the income arising from it, together with the interest income in the wife's name, were treated as belonging to the assessee.

Conclusion: The inclusion of the house property income and the interest income in the assessee's income was upheld, and the question was answered against the assessee.

Final Conclusion: The reference was decided in favour of the Revenue and the assessee failed.

Ratio Decidendi: Where the alleged source of investment or ownership in the spouse's name is unsupported by material on record, the resulting income may be treated as the assessee's income.

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