The examination of all the materials including the document revealed that the total companysideration was Rs.
The plot was purchased in the name of the assessees son Sri Ramakrish nan.
In the assessment, it was stated that the total companysid eration was Rs.80,000 out of which Rs.25,000 was the payment in respect of the portion purchased in the name of Sri Ramakrishnan.
P.S.S. Ekammai Achi and L.N. Perianna Chettiar had purchased a plot of land in T. Nagar on 13.4.1965 from Smt.
The I.A.C. imposed a penalty of Rs.
However, a raid made in the premises of V. Saroja and K.R. Sadayappan revealed the information that the assessee along with Smt.
From the Judgment and Order dated 9.3.1977 of the Madras High Court in T.C. Petition No.
The on money payment made by the assessee on behalf of his son was Rs.
The Income Tax Officer called for wealth state ments from the assessee The wealth statements did number reveal that the assessee had invested any amount in the plot of land in T. Nagar.
K.V. Saroja.
This sum of Rs.
CIVIL APPELLATE JURISDICTION Civil Appeal No.
T.M. Sampath and P.N. Ramalingam for the Respondent.
The Judgment of the Court was delivered by SABYASACHI MUKHARJI, CJ.
B. Ahuja and Ms. A. Subhashini for the Appellant.
The assessee filed an appeal to the Tribunal and companytended that in case of rejection of asses sees explanation for the source, the addition companyld number be held to be the companycealed income of the assessee, and relied on certain principles laid down by the companyrts.
The assessee filed a return of income on 12th July, 1968 declar ing No loss.
statement recorded on 9.10.1972 that the on money payment was made by him.
1248 of 1978.
362 of 1975.
The assessee is an individual who carried on business in distribution of films for the assessment year 1966 67.
Subsequently, the assessee filed a revised return on 4th January, 1969 declaring a net loss of Rs.9,490.
The appeal involves the assessment of income tax under the Income Tax Act, 1961 hereinafter referred to as the Act for the assessment year 1966 67.
1,000.
This is an appeal by special leave from the judgment and order of the Madras High Court dated 9th March, 1977.
18,750 was treated by the Income Tax Officer as the undisclosed income of the assessee and he initiated penalty proceedings under section 271 1 c of the Act for companycealment of income and referred the case to the I.A.C. for disposal as the minimum penalty leviable exceeded Rs.
18,750 for which the assessee companyld number adduce evidence to prove the nature and source of investment.
18,750 being equal to the income companycealed holding that the assessee had number discharged the burden cast upon him by the Explanation to section 271 1 c of the Act in number adducing any evidence that the plot was purchased by the assessees son out of his own funds and against the asses sees own.
1,40,000.
