1977 (8) TMI 68 - AT - Income Tax

Summary

Issues:
1. Addition of Rs. 12,000 to the total income of the assessee from undisclosed sources.
2. Rejection of the book results and estimation of profit at Rs. 12,000.

Detailed Analysis:
1. The issue of adding Rs. 12,000 to the total income of the assessee arose from a raid conducted by the Income-tax Department at the assessee's premises. The amount was found with the assessee but was not entered in his books of account. The assessee claimed that the money belonged to another individual, Sohanlal, who corroborated this claim. However, discrepancies in the explanations provided by the assessee and Sohanlal raised doubts. Sohanlal's travel details and the lack of corresponding entries in his firm's books undermined the credibility of their statements. The Appellate Assistant Commissioner confirmed the addition, concluding that the entry of Rs. 12,000 was not made in the normal course of business. The Appellate Tribunal upheld this decision, emphasizing the improbabilities in the explanations provided by the assessee and Sohanlal.

2. The second issue involved the rejection of the book results of the assessee's business in gold and silver ornaments. The tax authorities estimated the profit at Rs. 12,000 instead of the Rs. 9,867 reported by the assessee. This decision was based on the incomplete closure of the books of account and the absence of a balance sheet. The Appellate Tribunal upheld the tax authorities' decision, citing the facts and circumstances of the case. The Tribunal rejected the appeal by the assessee, affirming the estimation of profits at Rs. 12,000.