1971 (4) TMI 27

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..... t year 1945-46 including within the total income of the assessee an amount of Rs. 65,000 as the income of the assessee from undisclosed sources. On appeal by the assessee, the addition was maintained by the Appellate Assistant Commissioner and, thereafter, by the Income-tax Appellate Tribunal. The Income-tax Officer initiated penalty proceedings against the assessee and made an order under section .....

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..... nvincing evidence regarding the source of the deposits of Rs. 65,000 may be a good ground for treating the entire deposits as the assessee's income from undisclosed sources, so far as the assessment order is concerned. The evidence on record, in our opinion, is however insufficient to establish beyond reasonable doubt that the assessee actually earned that income and that it concealed the same. As .....

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