1975 (11) TMI 7

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....the present assessment year ? 2. Whether, on the facts and in the circumstance of the case, there is material to sustain the finding of the Tribunal that the amount of Rs. 1,00,000 was income of the assessee from undisclosed sources? " The assessment year is 1960-61. The previous year ends on March 31, 1960. The return was filed by the assessee showing an income of Rs. 5,944. In the course of the assessment proceedings it was found by the ITO that the assessee had an account in the names of two firms and in that account she had show deposits of Rs. 1 lakh made by her in those two firms. She was asked to explain the source of these to deposits but she has refused to do so by saying that the ITO has no jurisdiction to call for such explanat....

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....different from the assessment of income for those years and those earlier assessment orders are final and cannot be disturbed in a subsequent year of assessment. But we are not impressed by his contentions. The Tribunal has rejected the assessee's case that Rs. 1,00,000 was saved or accumulated by her in the earlier years, which has not been questioned in this reference. Further, the earlier assessment orders do not throw any light on the question of saving of this amount. Assessment order is final so far and as far as the particular year of assessment is concerned but it is merely a piece of evidence in a subsequent year of assessment. An earlier assessment order, like any other piece of evidence, may be accepted or rejected in a subseque....