SHANTI DEVI JALAN Vs. COMMISSIONER OF INCOME TAX

JUDGEMENT

(1.) The facts found and/or admitted in these proceedings are shortly as follows: The assessee, Shanti Devi Jalan and others, constituted a HUF styled as

(2.) At the relevant time, the assessee was a partner in a firm known as M/s. Soorajmull Nagurmull having a share of one anna, one pie therein.

(3.) In the course of assessment proceedings for the assessment year 1959-60 (the relevant accounting period being the year 2015 R.N., covering the period March 29, 1958 to April 16, 1959), the ITO found that one S.K. Jalan and one Sudha Bai, being a son and a daughter of late K.D. Jalan, were married, respectively, in June, 1958 and February, 1959. The marriage expenses were shown in the books of the firm, Soorajmull Nagurmull, to be Rs. 15,000 and Rs. 10,000, respectively. The ITO considered the said expenses to be inadequate. He noted that no amount was debited for the purchase of jewellery or as expenses for decoration. Another sum of Rs. 10,800 debited to the account of Shanti Devi Jalan in the books of the said firm stated to be for the purchase of jewellery for the daughter was not accepted by the ITO. The ITO took into account the social status of the family and the fact that it has been found by the Income-tax Investigation Commission that an expenditure of Rs. 1,00,000 used to be incurred in each of the marriages in the family of the partners of the said firm. The ITO estimated the expenses of the said two marriages at Rs. 1,50,000 and, deducting the expenses shown in the account, a sum of Rs. 1,25,000 was added to the assessee's income as income from undisclosed sources.