1984 (12) TMI 110

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....38 were discovered an seized. Thereafter the assessee filed the return for the year under consideration on26th Dec., 1981wherein the income was declared at Rs. 39,770. The ITO examined the income and expenditure statement filed by the assessee. The ITO noticed that the professional receipt shown by the assessee in the statement was made on estimate basis and not supported by any relevant bills and vouchers and the assessee failed to produce patient register/admission register indicating the operated upon and the amount of consolation charges/delivery charges/operation charges received from the partners. The ITO also noticed that the assessee was not making any significant withdrawal for household expense. He accordingly rejected the version....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....s of he assessee are fully explained there is no reasonable ground for making any addition on account of income from undisclosed sources. With regard to the withdrawal for household expenses the ld. counsel of the assessee contended that both the assessee and her husband are having income and they were not having any child. Since they were not a member of any club the household expenses are insignificant and met by her husband. There being no gift nor any expenditure incurred on ceremonial occasion during the year, there is no reasonable ground for making any addition on this account also. Since the income from profession has been correctly declared in the statement and the details of the income are duly furnished and the income shown durin....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....538 and the assessee was called upon to explain. The assessee explained the investments made by her upto the assessment year in question. Such investment as appearing in her capital account has already come up before the WTO in the wealth-tax assessment also. Since the ITO nor the WTO did not bring on record any concealed asset or income either from the book or from the evidences gathered during the search operation, we are unable to appreciate the addition of concealed income made by the authorities below on this account. If the assessee actually had undisclosed income it would either be available in the form of cash or fixed deposit or investment in house property or any other asset. There being no such unexplained investment detected by ....