Rejection of unreliable books of account permits estimated income assessment under Section 13 and leaves the finding to the tax authority.

Where the books of account are found unreliable, the assessing authority may reject them and estimate income on the basis of material indicating the real income. The determination whether the books are false or valueless lies within the assessing officer's province under Section 13 of the Indian Income-tax Act, 1922, and is not for the court to re-examine in reference proceedings. On that basis, the inclusion of the disputed amount as income was upheld and the question was answered against the assessee.

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Issues: Whether the assessing officer was justified in treating Rs. 1,350 as income after rejecting the books of account as unreliable.

Analysis: Where the accounts are found to be unreliable, the assessing officer is entitled to disregard them and adopt his own method of assessment on such material as appears to him to indicate the real income. The question whether the books should be rejected as false or valueless is within the assessing officer's province under Section 13 of the Indian Income-tax Act, 1922, and is not for the Court to re-determine in reference proceedings.

Conclusion: The assessing officer was justified in including the sum as income, and the question referred was answered in the affirmative, against the assessee.

Ratio Decidendi: When accounts are found unreliable, the assessing authority may reject them and make an estimate of income under Section 13 of the Indian Income-tax Act, 1922.

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