Reassessment and clubbing of spouse's share income upheld where the return omitted required disclosure of firm profits.

Reassessment under section 147(a) was treated as valid where the assessee had not disclosed the wife's share of firm profits in the return despite the disclosure requirement. On those admitted facts, the income was liable to be included in the assessee's hands under section 64(1), and the reassessment notices under section 148 were upheld. The reasoning was supported by the then-prevailing Allahabad High Court view relied on in the reassessment process and by the later Full Bench affirmation of that view.

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Issues: Whether the reopening of the assessments under section 147(a) and the addition of the wife's share income under section 64(1) were justified.

Analysis: The assessee had not disclosed the wife's income from her share in the profits of the firm in the returns, despite the specific requirement to do so under the return provisions. On the admitted facts, the reassessment notices under section 148 were validly issued and the income of the wife was rightly included in the assessee's hands. The reasoning was reinforced by the then-prevailing Allahabad High Court view relied upon in the reassessment proceedings and by the later Full Bench affirmation of that view.

Conclusion: The reopening of the assessments and the consequential additions were upheld.

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