(1.) The brief facts which are required to be stated are that the respondent assessee is the wife of Mr. S.D.Rajandran, an officer in M/s. Oriental Insurance Company Limited. She is the younger sister of Mrs. Prema Dyaneswaran, w/o Mr. Dyaneswaran. Mr. Dyaneswaran was an officer belonging to the Indian Administrative Services and was the then Chairman of M/s. Tamil Nadu Minerals Ltd.,
(2.) There was a search on Mr. Dyaneswaran under Section 132 of the Income Tax Act, 1961 (hereinafter referred to as 'the Act') on 19/20.01.1996. In connection with the said search, the residence of Mr. S.D. Rajendran, the husband of the respondent assessee was also searched.
(3.) According to the appellant, number of documents were seized in the course of the search evidencing the fact that the respondent assessee had 'undisclosed income' assessable to tax under Section 158BD read with Section 158BC. Proceedings were initiated under Section 158BD and notice under Section 158BC dated 07.03.1997, was issued to the respondent. The Notice was served on 18.03.1997, and the assessee filed her return of income in Form No. 2D in response to the notice on 26.05.1997. She admitted an undisclosed income of Rs. 2,31,098/- and paid tax of Rs. 1,38,659/-.