1982 (4) TMI 123

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....Rs. 2,820. He derives income from share of profit from the firm of M/s.Aggarwal Tube co., Ambala City and M/s.Jagan Nath & Co., Chandigarh, and has also interest income from M/s.Deep Chand Aggarwal & Sons and M/s. Ambala Pipe Co., Ambala. Before the assessment on the basis of this return was completed, there was a search conducted by the income-tax officials on the residential premises of the assessee on 20th April, 1977. During the course of search, Inter alia, the following assets were found: "(a) One chain with pendant gold :1 Total (b) One gold chain :1 Value is (c) Tops one set of pair :2 estimated (d) Rings :3 at (e) One pair of diamond ear-rings alleged to be artificial Rs.10,000 including....

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....of jewellery containing two rings, four ear tops, four necklaces and four bangles from her parents. The ITO considering that the affidavit of Smt. Anita Rani had not been verified fully by Smt. Shakuntala Devi discarded the affidavit and noticing certain contradiction added the value of Rs. 10,000 to the total income of the assessee treating the entire jewellery as belonging to the assessee. However, the value and source of investment of the jewellery on the person of Smt. Anita Rani which was as per annexure-I was accepted to be fair and reasonable. 4. In appeal, the AAC accepted version of the assessee that the addition on account of the value of these ornaments could not be made in the case of the assessee because his wife who was an ....