CIT v. Jawanmal Gemaji Gandhi

151 ITR 353High Court1985#5667 most cited

What is CIT v. Jawanmal Gemaji Gandhi authority for?

Undisclosed income earned in an earlier assessment year can form a concealed fund from which an assessee can subsequently draw to acquire assets.

20

judgments rely on this decision, according to BharatTax’s citation analysis of 366,005 Indian tax judgments — from 2016 to 2025.

Also referred to as

CIT v. Jawanmal Gemaji Gandhi · 151 ITR 353 · undisclosed income · earlier assessment year · concealed fund · subsequent acquisition · cash on hand · borrowed satisfaction

Sections most often in play

Section 142(1)Section 143(3)Section 147Section 148Section 153CSection 68Section 115BBESection 131

Issues it is cited on

period of holdingsection 148(2)live linkborrowed satisfactionprincipal commissioner of income-taxtangible materialescapement of incomereason to believereopening of assessmentcross objectionsection 131commissioner (appeals)

Judgments citing CIT v. Jawanmal Gemaji Gandhi

Sushil Mitruka, Siliguri vs. DCIT, Circle 1, Siliguri

In the result, the appeal of the Revenue is dismissed and the appeals of the assessee are allowed

ITA 2178/KOL/2025[2014-2015]Status: DisposedITAT Kolkata18 Dec 2025AY 2014-2015

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri SK Tulsian, ARFor Respondent: Shri S.B. Chakraborthy, DR
Section 139(1)Section 144BSection 147Section 148Section 148(2)

…here withdrawn, cash depositing etc. Perusal of the same confirms the existence of the cash on hand. The above reasoning has the strength of support by the ratio decidendi of a binding jurisdictional High court judgment in the case of Jawanmal Gemanji Gandhi (151 ITR 353), which is famous for the proposition that the undisclosed income of an assessee earned in an earlier assessment year can constitute a fund, though concealed, from which the assessee may draw subsequently. The held portion of the said judgment read as follows: Held, (i) that secret profits or undisclosed income of an assessee earned in an earlier…

Sushil Mitruka, Darjeeling vs. DCIT, Circle 1, Siliguri

In the result, the appeal of the Revenue is dismissed and the appeals of the assessee are allowed

ITA 1631/KOL/2025[2016-2017]Status: DisposedITAT Kolkata18 Dec 2025AY 2016-2017

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri SK Tulsian, ARFor Respondent: Shri S.B. Chakraborthy, DR
Section 139(1)Section 144BSection 147Section 148Section 148(2)

…here withdrawn, cash depositing etc. Perusal of the same confirms the existence of the cash on hand. The above reasoning has the strength of support by the ratio decidendi of a binding jurisdictional High court judgment in the case of Jawanmal Gemanji Gandhi (151 ITR 353), which is famous for the proposition that the undisclosed income of an assessee earned in an earlier assessment year can constitute a fund, though concealed, from which the assessee may draw subsequently. The held portion of the said judgment read as follows: Held, (i) that secret profits or undisclosed income of an assessee earned in an earlier…

Sushil Mitruka, Darjeeling vs. DCIT, Circle 1, Siliguri

In the result, the appeal of the Revenue is dismissed and the appeals

ITA 1630/KOL/2025[2015-2016]Status: DisposedITAT Kolkata18 Dec 2025AY 2015-2016

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

Section 139(1)Section 144BSection 147Section 148Section 148(2)

…here withdrawn, cash depositing etc. Perusal of the same confirms the existence of the cash on hand. The above reasoning has the strength of support by the ratio decidendi of a binding jurisdictional High court judgment in the case of Jawanmal Gemanji Gandhi (151 ITR 353), which is famous for the proposition that the undisclosed income of an assessee earned in an earlier assessment year can constitute a fund, though concealed, from which the assessee may draw subsequently. The held portion of the said judgment read as follows: Held, (i) that secret profits or undisclosed income of an assessee earned in an earlier…

DCIT, Circle-1, Siliguri vs. Sushil Mitruka, Siliguri

In the result, the appeal of the Revenue is dismissed and the appeals of the assessee are allowed

ITA 1613/KOL/2025[2017-18]Status: DisposedITAT Kolkata18 Dec 2025AY 2017-18

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri SK Tulsian, ARFor Respondent: Shri S.B. Chakraborthy, DR
Section 139(1)Section 144BSection 147Section 148Section 148(2)

…here withdrawn, cash depositing etc. Perusal of the same confirms the existence of the cash on hand. The above reasoning has the strength of support by the ratio decidendi of a binding jurisdictional High court judgment in the case of Jawanmal Gemanji Gandhi (151 ITR 353), which is famous for the proposition that the undisclosed income of an assessee earned in an earlier assessment year can constitute a fund, though concealed, from which the assessee may draw subsequently. The held portion of the said judgment read as follows: Held, (i) that secret profits or undisclosed income of an assessee earned in an earlier…

ACIT, Chennai vs. Rajagopalan, Chennai

In the result, the appeal of the revenue is dismissed

ITA 1443/CHNY/2025[2017-18]Status: DisposedITAT Chennai01 Dec 2025AY 2017-18

Bench: Shri Aby T Varkey & Shri S. R. Raghunatha

For Appellant: Shri. Y. Sridhar, F.C.AFor Respondent: Ms. E. Pavuna Sundari, CIT
Section 132Section 132(4)Section 143(3)Section 245D(4)Section 250Section 69

…d. There is no concept of duplication of taxation of the same income. We are taking support of the Hon’ble Apex Court’s decision in the case of Anantharam Veerasinghaiah (supra) the Hon’ble Bombay High Court in the case of CIT v. Jawanmal Gemaji Gandhi [1985] 151 ITR 353 (Bom), wherein it was held that: “secret profits or undisclosed income of an Appellant earned in an earlier assessment year can constitute a fund, though concealed, from which the Appellant may draw subsequently. In the reported case there was acquired gold during the latter half of the assessment year and it could be that the undisclosed income…

Dy.Commissioner of Income Tax, Central Circle-1, Aurangabad, Aurangbad vs. Shri Pankaj Ratilal Mugdiya, Aurangabad

In the result, the appeal filed by the Revenue is dismissed

ITA 958/PUN/2024[2021-22]Status: DisposedITAT Pune24 Feb 2025AY 2021-22

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2021-22

For Appellant: Shri Jaiprakash BairagraFor Respondent: Shri Arvind Desai, Addl CIT DR
Section 115BSection 131Section 132ASection 143(2)Section 153ASection 69A

…rudent person to not keep the unaccounted funds idle and make investment in assets, etc. for capital appreciation. Both source of income and its application cannot be added in the hands of the same Assessee. In the case of CIT v. Jawanmal Gemaji Gandhi (1985) 151 ITR 353 (Bom), it has been held that gold acquired in latter part of the year can be assumed to have been acquired from the undisclosed income earned in that very year and this undisclosed income constituted fund from which the asset was acquired. Similarly, the Hon'ble Supreme Court in the case of CIT v. S. Nelliappan (1967) 66 ITR 722 (SC) held that ev…

Welspun Corp Ltd, Mumbai vs. DCIT Cen Cir 22, Mumbai

In the result, the appeals filed by the revenue are dismissed and the appeals filed by the assessee are partly allowed for statistical purposes

ITA 3890/MUM/2016[2008-09]Status: DisposedITAT Mumbai03 Apr 2023AY 2008-09

Bench: Shri Prashant Maharishi & Shri Pavan Kumar Gadale

Section 143(3)Section 14ASection 32(1)(iia)

…IN THE INCOME TAX APPELLATE TRIBUNAL “J” BENCH, MUMBAI BEFORE SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER & SHRI PAVAN KUMAR GADALE, JUDICIAL MEMBER ITA No. 5063/Mum/2016 (2009-10) ITA No. 5166/Mum/2016 (2011-12) M/s. Welspun Corp Ltd, Vs. DCIT, Central Circle - 7th Floor, Welspun 22, (Now CC – 3(3)) House, Kamala Mill Room No. 465, 4th Compund, SB Marg, Floor,AayakarBhavan, Lower Parel, Mumbai-400020. Mumbai -400013. "थायी लेखा सं./जीआइआर सं./PAN/GIR No. : AAACW0744L Appellant .. Respondent ITA No. 5483/Mum/2016 (2009-10) ITA No. 5044/Mum/2016 (2011-12) DCIT, Central Circle - Vs. M/s.Welspun Corp Ltd 22, (Now…

Ganigara Rekha Venugopal, Devanahalli vs. Assistant Commissioner of Income Tax, Circle-6(3)(1), Bangalore

In the result, appeal of the assessee is allowed

ITA 1005/BANG/2022[2012-13]Status: DisposedITAT Bangalore08 Feb 2023AY 2012-13

Bench: Shri N. V. Vasudevanassessment Year : 2012-13 Smt. Ganigara Rekha Venugopal, Vs. Acit, 344 Ganigara Beedi, 6Th Ward, Central Circle – 6(3)(1), Devanahalli Town, Bengaluru. Devanahalli – 562 110. Pan : Aewpv 4890 F Appellant Respondent Assessee By : Shri. Cuddapah Ramesh, Ca Revenue By : Shri. Ganesh R. Ghale, Standing Counsel Date Of Hearing : 01.02.2023 Date Of Pronouncement : 08.02.2023 O R D E R This Is An Appeal By The Assessee Against The Order Dated 08.06.2022 Of National Faceless Appeal Centre (Nfac), Delhi, Relating To Assessment Year 2012-13. 2. The Assessee Is An Individual. In The Return Of Income Filed 11.1.2012 For Ay 2011-12, The Assessee Declared Total Income Of Rs.4,66,770/- & Agricultural Income Of Rs.22,21,750 (Comprising Of Rs. 46,750/- From Lands At Devanahalli Village & Rs.21,75,000/- From Lands At Manepalli Village). In An Assessment Completed U/S.143(3) Of The Act Dated 7.3.2014, The Ao Treated Agricultural Income From Devanahalli Village Of A Sum Of Rs.18,17,840/- As Unexplained & Treated The Same As Income From Other Sources. Besides The Above The Assessee Had Shown An Advance Lease Rental Received On Lease Of Agricultural Lands Of Rs.43,50,000/-. The Same Page 2 Of 6

For Appellant: Shri. Cuddapah Ramesh, CAFor Respondent: Shri. Ganesh R. Ghale, Standing Counsel
Section 143(3)Section 68

…of the Act. When an income is taxed / addition is made to taxable income in an earlier year, the assessee may claim that the income arising in subsequent year / subsequent period is sourced out of the income taxed earlier. CIT v. Jawanmal Gemaji Gandhi (1985) 151 ITR 353 (Bom). The AO and the CIT(A) have proceeded on the presumption that the assessee is claiming credit on the agricultural income of Rs.21,75,000/- declared in Assessment Page 6 of 6 Year 2011-12 is factually incorrect. The credit is claimed only for the advance shown in the balance sheet that was treated as unexplained credit under section 68 of t…

Luxora Infrastructure Pvt. Ltd., Mumbai vs. DCIT Central Circle 2 (1), Mumbai

In the result, the appeals of the assessee are allowed

ITA 1293/MUM/2019[2012-13]Status: DisposedITAT Mumbai21 Apr 2020AY 2012-13

Bench: Shri Rajesh Kumar & Shri Ram Lal Negi

For Appellant: Shri K.P. Dewani, A.RFor Respondent: Shri Rajiv Harit, D.R
Section 132Section 132(4)Section 143(3)Section 153ASection 234ASection 69C

…IN THE INCOME TAX APPELLATE TRIBUNAL, MUMBAI BENCH “A”, MUMBAI BEFORE SHRI RAJESH KUMAR, ACCOUNTANT MEMBER AND SHRI RAM LAL NEGI, JUDICIAL MEMBER ITA Nos.1293, 1294, 1295 & 1296/M/2019 Assessment Years: 2012-13, 2013-14, 2014-15 & 2015-16 M/s. Luxora DCIT, Infrastructure Pvt. Ltd., Central Circle -2(1), 1207, 12th Floor, Pratishtha Bhavan, A Wing, 8th Floor, 02 Commercial Building, Mumbai Vs. 23-24, Minerva Industrial Estate, Off. LBS Road, Mulund (W), Mumbai - 80 PAN: AABCL2854K (Appellant) (Respondent) Present for: Assessee by : Shri K.P. Dewani, A.R. Revenue by : Shri Rajiv Harit, D.R. Date of Hearing : 26.…

Sanjeeb Kumar Singh, Kolkata vs. ACIT, Circle - 40, Kolkata

In the result, the appeal of the assessee is partly allowed

ITA 946/KOL/2018[2013-14]Status: DisposedITAT Kolkata27 Dec 2019AY 2013-14

Bench: "ी जे. सुधाकर रे"डी, लेखा सद"य एवं/And "ी ऐ. ट". वक", "यायीक सद"य) [Before Shri J. Sudhakar Reddy, Am & Shri A. T. Varkey, Jm]

Section 133ASection 143(2)Section 24

…he judgment of the Hon’ble Supreme Court in the case of Anantharam Veerasinghaiah & Co Vs. CIT reported in 123 ITR 457 which was followed by the Hon'ble Bombay High Court & Punjab & Haryana High Court in the cases of CIT Vs. Jawanmal Gemaji Gandhi reported in 151 ITR 353 and CIT Vs. Prem Chand Jain reported in 189 ITR 320 respectively wherein it was held as follows: “8. There can be no escape from the proposition that the secret profits or undisclosed income of an assessee earned in an earlier assessment year may constitute a fund, even though concealed, from which the assessee may draw subsequently for meeting…

ACIT, CC-1(2), Kolkata vs. Vivek Rohatgi, Kolkata

In the result, the appeals of the assessee and revenue are partly allowed

ITA 1437/KOL/2016[2013-14]Status: DisposedITAT Kolkata30 Oct 2019AY 2013-14

Bench: Shri A. T. Varkey, Jm & Dr. (Shri) Arjun Lal Saini, Am ]

Section 131Section 132Section 132(4)Section 69A

…n the decision of Hon'ble Supreme Court in the case of Anantharam Veerasinghaiah & Co Vs. CIT reported in 123 ITR 457, which was followed by the Hon'ble Bombay High Court & Punjab & Haryana High Court in the cases of CIT Vs. Jawanmal Gemaji Gandhi reported in 151 ITR 353 and CIT Vs. Prem Chand Jain reported in 189 ITR 320 respectively. 14. We have considered the rival submissions and perused the documents, which were found and seized in the course of search and impounded in the course of survey. We have also examined the orders of authorities below and considered the rival submissions. On due consideration of th…

Vivek Rohatgi, Kolkata vs. DCIT, CC-1(2), Kolkata

In the result, the appeals of the assessee and revenue are partly allowed

ITA 1293/KOL/2016[2013-14]Status: DisposedITAT Kolkata30 Oct 2019AY 2013-14

Bench: Shri A. T. Varkey, Jm & Dr. (Shri) Arjun Lal Saini, Am ]

Section 131Section 132Section 132(4)Section 69A

…n the decision of Hon'ble Supreme Court in the case of Anantharam Veerasinghaiah & Co Vs. CIT reported in 123 ITR 457, which was followed by the Hon'ble Bombay High Court & Punjab & Haryana High Court in the cases of CIT Vs. Jawanmal Gemaji Gandhi reported in 151 ITR 353 and CIT Vs. Prem Chand Jain reported in 189 ITR 320 respectively. 14. We have considered the rival submissions and perused the documents, which were found and seized in the course of search and impounded in the course of survey. We have also examined the orders of authorities below and considered the rival submissions. On due consideration of th…

DCIT-Central Circle-Xxviii, Kolkata vs. Shri Chandra Prakash Banthia, Kolkata

In the result, the appeal of the revenue is dismissed

ITA 2404/KOL/2013[2011-12]Status: DisposedITAT Kolkata06 Dec 2017AY 2011-12

Bench: : Shri P.M. Jagtap & Shri S.S.Viswanethra Ravi

For Appellant: Shri Sallong Yaden, Addl.CIT, ld. Sr.DRFor Respondent: Shri A.K. Upadhyay, Advocate, ld.AR
Section 132Section 132(4)Section 142(1)Section 143(2)Section 143(3)

…n the decision of Hon’ble Supreme Court in the case of Anantharam Veerasinghaiah & Co Vs. CIT reported in 123 ITR 457, which was followed by the Hon’ble Bombay High Court & Punjab & Haryana High Court in the cases of CIT Vs. Jawanmal Gemaji Gandhi reported in 151 ITR 353 and CIT Vs. Prem Chand Jain reported in 189 ITR 320 respectively. Relevant portion of CIT-A order is reproduced herein below:- “11. I also find merit and substance in the alternate submission of the assessee. By AO’s own admission, the assessee conducted activity of money handling throughout the financial year 2010-11; and, the commission from c…

Sterling Biotech Ltd, Mumbai vs. Pr CIT Cen 1, Mumbai

In the result, all appeals filed by assessee are allowed

ITA 2756/MUM/2016[2012-13]Status: DisposedITAT Mumbai29 Jun 2016AY 2012-13

Bench: Shri Shailendra Kumar Yadav & Shri Rajesh Kumar.

For Appellant: Shri Vijay Mehta, A.RFor Respondent: Shri Manjunathaswamy
Section 132Section 143(3)Section 153ASection 263Section 69

…be said that no inquiry has been made with regards to source of cash received. We find ITA Nos.2750 to 2756/Mum/16 A.Ys. 06-07 to 12-13 [Sterling Biotech Ltd. vs. Pr.CIT] Page 28 that Hon’ble Bombay High Court in case of CIT vs. Jawanmal Gemaji Gandhi (1985) 151 ITR 353 (Bom) held that secret profits or undisclosed income of an assessee earned in an earlier assessment year can constitute a fund, though concealed, from which assessee may draw subsequently. In the instant case, assessee acquired gold during the later half of assessment year and it could be that the undisclosed income earned in that very year const…

Sterling Biotech Ltd, Mumbai vs. Pr CIT Cen 1, Mumbai

In the result, all appeals filed by assessee are allowed

ITA 2755/MUM/2016[2011-12]Status: DisposedITAT Mumbai29 Jun 2016AY 2011-12

Bench: Shri Shailendra Kumar Yadav & Shri Rajesh Kumar.

For Appellant: Shri Vijay Mehta, A.RFor Respondent: Shri Manjunathaswamy
Section 132Section 143(3)Section 153ASection 263Section 69

…be said that no inquiry has been made with regards to source of cash received. We find ITA Nos.2750 to 2756/Mum/16 A.Ys. 06-07 to 12-13 [Sterling Biotech Ltd. vs. Pr.CIT] Page 28 that Hon’ble Bombay High Court in case of CIT vs. Jawanmal Gemaji Gandhi (1985) 151 ITR 353 (Bom) held that secret profits or undisclosed income of an assessee earned in an earlier assessment year can constitute a fund, though concealed, from which assessee may draw subsequently. In the instant case, assessee acquired gold during the later half of assessment year and it could be that the undisclosed income earned in that very year const…

Sterling Biotech Ltd, Mumbai vs. Pr CIT Cen 1, Mumbai

In the result, all appeals filed by assessee are allowed

ITA 2754/MUM/2016[2010-11]Status: DisposedITAT Mumbai29 Jun 2016AY 2010-11

Bench: Shri Shailendra Kumar Yadav & Shri Rajesh Kumar.

For Appellant: Shri Vijay Mehta, A.RFor Respondent: Shri Manjunathaswamy
Section 132Section 143(3)Section 153ASection 263Section 69

…be said that no inquiry has been made with regards to source of cash received. We find ITA Nos.2750 to 2756/Mum/16 A.Ys. 06-07 to 12-13 [Sterling Biotech Ltd. vs. Pr.CIT] Page 28 that Hon’ble Bombay High Court in case of CIT vs. Jawanmal Gemaji Gandhi (1985) 151 ITR 353 (Bom) held that secret profits or undisclosed income of an assessee earned in an earlier assessment year can constitute a fund, though concealed, from which assessee may draw subsequently. In the instant case, assessee acquired gold during the later half of assessment year and it could be that the undisclosed income earned in that very year const…

Sterling Biotech Ltd, Mumbai vs. Pr CIT Cen 1, Mumbai

In the result, all appeals filed by assessee are allowed

ITA 2753/MUM/2016[2009-10]Status: DisposedITAT Mumbai29 Jun 2016AY 2009-10

Bench: Shri Shailendra Kumar Yadav & Shri Rajesh Kumar.

For Appellant: Shri Vijay Mehta, A.RFor Respondent: Shri Manjunathaswamy
Section 132Section 143(3)Section 153ASection 263Section 69

…be said that no inquiry has been made with regards to source of cash received. We find ITA Nos.2750 to 2756/Mum/16 A.Ys. 06-07 to 12-13 [Sterling Biotech Ltd. vs. Pr.CIT] Page 28 that Hon’ble Bombay High Court in case of CIT vs. Jawanmal Gemaji Gandhi (1985) 151 ITR 353 (Bom) held that secret profits or undisclosed income of an assessee earned in an earlier assessment year can constitute a fund, though concealed, from which assessee may draw subsequently. In the instant case, assessee acquired gold during the later half of assessment year and it could be that the undisclosed income earned in that very year const…

Sterling Biotech Ltd, Mumbai vs. Pr CIT Cen 1, Mumbai

In the result, all appeals filed by assessee are allowed

ITA 2752/MUM/2016[2008-09]Status: DisposedITAT Mumbai29 Jun 2016AY 2008-09

Bench: Shri Shailendra Kumar Yadav & Shri Rajesh Kumar.

For Appellant: Shri Vijay Mehta, A.RFor Respondent: Shri Manjunathaswamy
Section 132Section 143(3)Section 153ASection 263Section 69

…be said that no inquiry has been made with regards to source of cash received. We find ITA Nos.2750 to 2756/Mum/16 A.Ys. 06-07 to 12-13 [Sterling Biotech Ltd. vs. Pr.CIT] Page 28 that Hon’ble Bombay High Court in case of CIT vs. Jawanmal Gemaji Gandhi (1985) 151 ITR 353 (Bom) held that secret profits or undisclosed income of an assessee earned in an earlier assessment year can constitute a fund, though concealed, from which assessee may draw subsequently. In the instant case, assessee acquired gold during the later half of assessment year and it could be that the undisclosed income earned in that very year const…

Sterling Biotech Ltd, Mumbai vs. Pr CIT Cen 1, Mumbai

In the result, all appeals filed by assessee are allowed

ITA 2751/MUM/2016[2007-08]Status: DisposedITAT Mumbai29 Jun 2016AY 2007-08

Bench: Shri Shailendra Kumar Yadav & Shri Rajesh Kumar.

For Appellant: Shri Vijay Mehta, A.RFor Respondent: Shri Manjunathaswamy
Section 132Section 143(3)Section 153ASection 263Section 69

…be said that no inquiry has been made with regards to source of cash received. We find ITA Nos.2750 to 2756/Mum/16 A.Ys. 06-07 to 12-13 [Sterling Biotech Ltd. vs. Pr.CIT] Page 28 that Hon’ble Bombay High Court in case of CIT vs. Jawanmal Gemaji Gandhi (1985) 151 ITR 353 (Bom) held that secret profits or undisclosed income of an assessee earned in an earlier assessment year can constitute a fund, though concealed, from which assessee may draw subsequently. In the instant case, assessee acquired gold during the later half of assessment year and it could be that the undisclosed income earned in that very year const…

Sterling Biotech Ltd, Mumbai vs. Pr CIT Cen 1, Mumbai

In the result, all appeals filed by assessee are allowed

ITA 2750/MUM/2016[2006-07]Status: DisposedITAT Mumbai29 Jun 2016AY 2006-07

Bench: Shri Shailendra Kumar Yadav & Shri Rajesh Kumar.

For Appellant: Shri Vijay Mehta, A.RFor Respondent: Shri Manjunathaswamy
Section 132Section 143(3)Section 153ASection 263Section 69

…be said that no inquiry has been made with regards to source of cash received. We find ITA Nos.2750 to 2756/Mum/16 A.Ys. 06-07 to 12-13 [Sterling Biotech Ltd. vs. Pr.CIT] Page 28 that Hon’ble Bombay High Court in case of CIT vs. Jawanmal Gemaji Gandhi (1985) 151 ITR 353 (Bom) held that secret profits or undisclosed income of an assessee earned in an earlier assessment year can constitute a fund, though concealed, from which assessee may draw subsequently. In the instant case, assessee acquired gold during the later half of assessment year and it could be that the undisclosed income earned in that very year const…

CIT v. Jawanmal Gemaji Gandhi (151 ITR 353) — Cited in 20 Judgments | BharatTax