Photocopy receipt and corroborative statements can support income-tax assessment when factual findings are unchallenged

A photocopy of a receipt, supported by the assessee's own recorded statements and not rebutted by contrary evidence, was treated as valid material in income-tax assessment. The Tribunal held that an Assessing Officer is not confined to technical rules of evidence and may rely on relevant material gathered during enquiry. The High Court treated the findings that the property was sold with additional cash consideration as concurrent findings of fact, not shown to be illegal or perverse, and held that no substantial question of law arose. Interference was therefore unwarranted.

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Issues: Whether a photocopy of a receipt, supported by recorded statements and not rebutted by the assessee, could be relied upon in income-tax assessment, and whether any substantial question of law arose from the concurrent factual findings.

Analysis: The authorities found that the assessee and co-owners had sold the property and that the investigation wing obtained a photocopy of a receipt showing receipt of additional cash consideration. The Tribunal held that, for assessment purposes, the Assessing Officer is not confined to technical rules of evidence and may act on relevant material gathered during enquiry. It further found that the receipt was specific and corroborated by the assessee's own statements recorded on oath, while no rebuttal evidence was produced to displace its contents. The High Court treated these as pure findings of fact, not shown to be illegal or perverse, and therefore held that no substantial question of law arose.

Conclusion: The photocopy receipt and corroborative statements were valid material for assessment, and the concurrent findings did not justify interference.

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