1977 (9) TMI 44

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.... 1966 he advanced a sum of Rs. 55,000 to his minor son Sham H. Punjabi. The amount was disclosed in the balance sheet as at 31st March, 1966 but the name of the son nor any other name was not disclosed against it. In the balance sheets as at 31st March, 1967 and 31st March, 1963 the name entered against the amount of Rs. 55,000 was Universal Automobiles, Delhi. 4. The assessee filed returns for asst. yrs. 1966-67, 1967-68 & 1968-69 on or about 28th Sept., 1966, 27th Sept., 1967 and 24th July, 1968, respectively. He did not declare therein any income from Universal Automobiles. It appears that he filed copies of the balance sheets including therein particulars as stated in the preceding para. 5. The ITO made assessments for the three res....

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....the contentions of the assessee challenging the validity of the re-opening of the assessments as also the merits of the case for the disputed additions made under s. 64. 10. Mr. Jain, learned Representative of the assessee, raised or pressed before us a number of points attacking the validity of the action intitated under s. 147(a) and the assessments made accordingly as also the merits of the addition. It is not necessary to deal however with all these points because, as we shall presently discuss we find that the reassessments has to be cancelled on the preliminary finding that the re-opening of the assessments was not relevant. 11. The relevant contention is that there is nothing to show that the assessee has not fully and truly disc....