Search assessment requires corroborating evidence; a statement alone was insufficient to treat wife's income as undisclosed income.

In search assessments under Chapter XIVB of the Income-tax Act, 1961, undisclosed income must be established from material found during the search. A statement recorded under section 132(4), without corroborating incriminating documents, was held insufficient to treat income shown in the wife's name as the assessee's undisclosed income. The Tribunal's appreciation of the evidence and application of the statutory provisions were upheld, and no substantial question of law arose.

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Issues: Whether income shown in the name of the assessee's wife could be treated as the assessee's undisclosed income under Chapter XIVB of the Income-tax Act, 1961, and whether the appeal raised any substantial question of law.

Analysis: The assessment was made under Chapter XIVB, which contemplates computation of undisclosed income on the basis of material found during search. No documents were found in the search to show that the wife's disclosed income was the assessee's income. The assessment authority had relied mainly on the statements recorded during search, but the Tribunal found that such material, without supporting incriminating documents, was insufficient to hold that the income belonged to the assessee. The Tribunal's appreciation of the evidence and application of the statutory provisions was found to be correct.

Conclusion: The income shown in the wife's name was not liable to be treated as the assessee's undisclosed income, and no substantial question of law arose.

Final Conclusion: The appeal failed at the threshold and was dismissed.

Ratio Decidendi: In search assessments under Chapter XIVB of the Income-tax Act, 1961, undisclosed income must be supported by material found during search, and a statement recorded under section 132(4) without corroborating incriminating evidence is insufficient to fasten the income in the hands of the assessee.

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