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Issues:
1. Validity of assessment made under section 34(1)(a) of the Income-tax Act. Analysis: The case involved a reference under section 66(1) of the Income-tax Act regarding the validity of an assessment made under section 34(1)(a). The assessee, a Hindu undivided family, had certain cash credits included in its total income for the assessment year 1947-48. The Appellate Assistant Commissioner initially allowed the appeal, stating that the nature and source of the cash credits remained unexplained. Subsequently, the Income-tax Officer issued a notice under section 34, subjecting the amount to tax under section 34(1)(a) along with additional amounts. The Appellate Assistant Commissioner and the Income-tax Appellate Tribunal had differing opinions on the applicability of section 34(1)(a) to the case. The Tribunal held that the mere presence of entries in the account books did not constitute disclosure of the information contained in those entries to the Income-tax Officer. Therefore, there was a failure on the part of the assessee to disclose all material facts necessary for the assessment. The Tribunal concluded that the provisions of section 34(1)(a) were applicable. Additionally, the Tribunal determined that the assessment was within the prescribed limitation period of eight years from the end of the assessment year. Alternatively, the case was considered under section 28(1)(c), where reassessment could be completed within eight years. This provision justified the reassessment as an assessment under section 23. Ultimately, the court held that the proceedings under section 34(1)(a) were legally justified, and the assessment was completed within the specified time limit. The court answered the reference in the affirmative, affirming the validity of the assessment under section 34(1)(a). The department was awarded costs of Rs. 200.
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