1978 (1) TMI 105

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.... to the appellant, was Rs. 20,000 for asst. yr. 1964-65 and Rs. 25,000 for asst. yr. 1965-66. The ITO at the time of making the original assessments added to the cost of construction admitted by the appellant Rs. 5000 for asst. yr. 1964 65 and Rs. 12,000 for asst. yr. 19650-66. A raid in the premises of the appellant's co brother revealed that he had paid on money while purchasing a building at 26, Sembudoss St. Madras. Since the appellant was managing the affairs of his co brother, the ITO concluded that the appellant must have also paid similar on money for the purchase of the property at 1-28 and 2-28 Maracair Labbai St., Madras. In the valuation report filed for purposes of wealth tax assessment the appellants valuer estimated the marke....

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....tioned are:- (a) Raid conducted in the premises of the appellant's co-brother revealing payment of on money by the appellant's co-brother when he purchased a building at 26, Sembudoss St., Madras; and (b) In the valuation report filed by the appellant in the subsequent year for purposes of wealth tax assessment, the market value of the property was shown at Rs. 95,000. 6. `Taking ground (a), the payment of co money by the appellant's co-brother has nothing to do with the cost of construction of the property purchased by the appellant. Taking ground (b), the approved valuer has estimated the market value of the property for purposes of wealth tax assessment for the subsequent assessment year and this again has no bearing or relevanc....