Burden of proving non-taxable source of receipt rests on assessee once income character is established.

A receipt found on the evidence to be income of the assessee in the relevant previous year is taxable as income from an undisclosed source; the revenue need not prove the exact business activity or precise origin once taxability is established. The assessee bears the burden of substantiating any non-taxable explanation for the receipt, and a rejected claim that the money was merely returned cash will not displace the finding of income. On that basis, the sum was correctly brought to tax.

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Issues: Whether the sum of Rs. 2,20,000 remitted to the assessee constituted taxable income from an undisclosed source, and whether the revenue was required to establish the exact source or business activity from which the receipt arose.

Analysis: The explanation that the remittances represented the return of cash earlier sent from Calcutta was rejected on the evidence, and the finding that the receipt was income from an undisclosed source was sustained. Once the authorities found that the amount was income of the assessee of the relevant previous year, the precise source from which it arose was not material for taxability. The assessee, having failed to establish the asserted non-taxable origin of the receipt, could not insist that the department prove the exact business activity or source before bringing the amount to tax.

Conclusion: The receipt of Rs. 2,20,000 was rightly treated as taxable income, and the revenue's appeal succeeded on the question referred.

Ratio Decidendi: Once a receipt is found to be income of the assessee, taxability does not depend on the revenue proving the exact source or precise nature of the undisclosed activity; the burden rests on the assessee to establish any non-taxable explanation.

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