SARDAR KEHAR SINGH Vs. COMMISSIONER OF INCOME TAX

JUDGEMENT

(1.) THE petitioner, a Hindu undivided family, was assessed to income-tax. In 1968, a plot of land at Chandigarh in sector 17-C was purchased. Constructions were, thereafter, started over the plot in 1969. It continued up to 1975, relevant for the assessment year 1976-77. During the assessment years 1968-69 to 1976-77, the petitioner disclosed investments in the construction of the house at Chandigarh as under : <FRM>JUDGEMENT_769_ITR195_1992Html1.htm</FRM>

(2.) THUS, the total investment up to 1976-77 shown by the petitioner was in the sum of Rs. 7,68,897.

(3.) ON the ground that the assessee had not fully and truly accounted for the investment made in the property, the Income-tax Officer reopened the original assessments made for the year 1974-75 by issuing a notice under Section 147(a) read with Section 148 of the Act. Ultimately, reassessment was made by making an addition of Rs. 3,14,907 during this assessment year. Thus, the amount of unexplained investment was reduced from Rs. 3,26,872 to Rs. 3,14,907. Similar action was taken by the Income-tax Officer in respect of the subsequent year 1975-76 for which an addition of Rs. 70,670 was made in the assessment order.