1974 (6) TMI 13

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....,000 was the appellant's income from undisclosed sources was perverse in the sense that no reasonable man could come to it on the materials on record ? (3) Whether the said conclusion was based on conjectures, surmise or suspicion and on a failure to consider the relevant evidence on record ?" As this reference is capable of being disposed of on a short point, namely, whether the sum of Rs. 1,38,000 as income from undisclosed sources can be assessed for the assessment year 1947-48 or not, it is unnecessary for us to go into the facts in detail. For the assessment year 1947-48, the relevant accounting year is the calendar year 1946. The Income-tax Officer, upon scrutiny of the material before him, assessed the assessee to the total amoun....

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.... If for the assessment year 1947-48, the sum of Rs. 1,38,000 as income from undisclosed sources cannot be regarded as part of the income, then naturally question No. 1 has to be answered in favour of the assessee. On January 19, 1946, the assessee made a declaration in the form prescribed under section 6 of the High Denomination Bank Notes (Demonetisation) Ordinance, 1946, being Ordinance No. 3 of 1946. As shown by particulars in item 14 of the declaration she has encashed 238 notes of Rs. 1,000 each. While assessing the assessee for the assessment year 1947-48, the Income-tax Officer directly applied his mind to the question whether the sum of Rs. 2,38,000 representing 238 notes of Rs. 1,000 each was her income for the assessment year 1947....