9911796707
TMI Blog1983 (5) TMI 72X X X X Extracts X X X X X X X X Extracts X X X X ..... s income of Jagat Ram& Sons,Delhi (1854) 463 . . 3 . . Share Inunexplained investment of the firm M/s Jagat & Sons Ram,Delhiand not reflected in the return (11049) 2,762 3,225 . 4 . . 4. In the assessment of the assessee for asst. yr. 1963-64,the WTO besides the aforesaid addition of Rs. 3,225 made the following additions: "In Income-tax proceeding unexplained investments have been assessed at Rs. 37,450. These do not find place in the returned wealth. This will, therefore, be added to this wealth. . 37,450 Assessee is a partner in the firm M/s French India Importing CorporationPondicherryhaving 50% share. In this Income-tax assessment, share of the assessee from the said firm not disclosed to the department was taken at Rs. 30,000.This will also be added to this wealth . 30,000 Assessee is also a partner having 25% share in the firm M/s Jagat Ram & Sons Delhi. The case of the firm, concealed business income and income from undisclosed sources has been assessed for the assessment year 1963-64. Assessee's share from that concealed income will also have to be taken as his wealth as under : 2,357 . Share in concealed business income Share in concealed income ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 5,184 37,496 " 6. In the assessment of the assessee for asst. yr. 1965-66, the assessee in addition to the additions of the Rs. 30,000 of asst. yr. 1963-64 and Rs. 72,102, Rs. 17,600, Rs. 31,780, and Rs. 37,496 of asst. yr. 1964-65 made an addition of Rs. 11,615 by observing as under: "Add : Concealed income from the firm M/s Jagat & Sons,Delhifor the assessment years. 1962-63 to 1965-66 not reflected in the returned wealth : . . Rs. . 1962-63 3,225 . 1963-64 3,773 . 1964-65 2,946 . 1965-66 1,671 . . . 11.615" 7. When we come to the assessment of the made to the net wealth as under: assessee for asst. yr. 1966-67, the additions "Additions (i) There was accretion in the wealth of the assessed income. The reply of the show cause notice has already been discussed above and amount as detailed below are added back in the wealth : . 1963-64 30,000 . 1965-66 2,274 . 1966-67 49,947 . . . 82,221 Case for asst. yr. 1964-65 has been set aside where there was an accretion of Rs. 37,496 in the capital as per income assessed. The income will be examined when the assessment is reframed under the Income-tax Act. . (ii) Deduction in the capital of M/s French ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... income which according to my opinion have also resulted in concealing the particulars of wealth correspondingly. I, therefore proceed to enhance the wealth of the assessee as detailed below: .1962-63 3,225 . 1963-64 3,773 . 1964-65 2,946 . 1965-66 1,631 . 1966-67 1,570 . . . 13,145 . (b) In M/s French India Importing Corpn the assessee holds 1/2 share. The capital standing in his account-books is taken as the value of his interest in this concern 43,289 Additions: .(i) There was accretion in the wealth of the assessee on the basis of returned and the assessed income. The reply of the show cause notice has already been discussed above and amounts as detailed below are added back in the returned wealth : . 1963-64 30,000 . 1965-66 2,274 . 1966-67 49,947 . . . 82,221 Case for assessment year 1964-65 has been set the aside where there was on accretion of Rs. 37,496 in capital as per income assessed. The issue will be examined when the assessment is reframed under the Income-tax Act. . (ii) Reduction in the capital of M/s French India Importing Corpn., Pondicherry during the financial year 1963-64 not accepted for the reasons given in the order fo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the basis of returned and the assessed income. The reply of the show cause notice has already been discussed above and amounts as detailed below are added back in the returned wealth : . 1963-64 30,000 . 1965-66 2,274 . 1966-67 49,947 . . . 82,221 Case for assessment year 1964-65 has been set aside where there was on accretion of Rs.37,496 in the capital as per income assessed. The issue will be examined when the assessment is reframed under the IT Act. . (ii) Reduction in the capital of M/s French India Importing Corpn., Pondicherry during the financial year 1963-64 not accepted for the reasons given in the order for the asst. yr. 1965-66 are added : 72,102 (iii) Withdrawals from M/s French India Importing Corpn.,Pondicherryduring the financial year 1964-65 not accepted for the reasons given in the order in the income tax proceedings for the asst. yr. 1965-66 are added : 17,600 (c) Unexplained investment not reflected in the returned wealth assessed for the asst. yr. 1964-65 is also added : 31,780 (d) Capital as per account books of M/s Jagsons Traders,Delhi. 51,287 (e) Capital as per account books of Greenfield Poultry farm 10,546 (f) Deposit in the bank ..... X X X X Extracts X X X X X X X X Extracts X X X X
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