Survey statement cannot by itself justify clubbing income where separate business activity and independent tax records are shown.

A statement recorded during survey, by itself, is insufficient to justify clubbing one spouse's business income with the other's where independent material shows separate and genuine business activity. The assessee and his wife carried on bidi trading at different addresses, held separate tax registrations, filed independent income tax returns, and maintained tax-audited accounts. On those facts, the Revenue's reliance on the survey statement did not displace the documentary evidence of separate operations, and the addition was not sustained.

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Issues: Whether the business income of the assessee's wife could be clubbed with the assessee's income on the basis of a statement recorded during survey proceedings.

Analysis: The assessee and his wife were found to be carrying on bidi trading in their respective individual capacities at different addresses, with separate tax registrations and independent income tax returns. The accounts were tax audited. The Revenue relied mainly on the statement recorded during survey, but such statement was not treated as sufficient evidence to displace the separate and independent business activity shown on record.

Conclusion: The addition by clubbing the wife's business income with the assessee's income was not sustained, and the issue was decided in favour of the assessee.

Ratio Decidendi: A statement recorded during survey, by itself, has no evidentiary value sufficient to justify clubbing of income when independent material shows separate business activity and separate assessment of the other person.

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