How many judgments cite Govindarajulu Mudaliar v. CIT?

306 judgments on BharatTax cite Govindarajulu Mudaliar v. CIT (34 ITR 807), spanning 2009 to 2026.

Which sections of the Income Tax Act does Govindarajulu Mudaliar v. CIT come up under?

It is most often cited in judgments turning on Section 68, Section 143(3), Section 115BBE, Section 142(1), Section 69A, Section 69.

Govindarajulu Mudaliar v. CIT

34 ITR 807Supreme Court of India1958#255 most cited

What is Govindarajulu Mudaliar v. CIT authority for?

The onus lies on the assessee to satisfactorily explain the source and nature of any unexplained cash or credit entries; if they fail to do so, the amount is treated as taxable income. The Income Tax Department is not required to locate the exact source of such funds, and this principle applies even if Section 68 is not strictly invoked.

306

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2009 to 2026.

Also referred to as

Govindarajulu Mudaliar v CIT · Section 68 · Section 69 · Section 69A · unexplained cash credit · onus of proof · source and nature of credit · creditworthiness · department not required to locate source · taxable income · general principles of taxation

Sections most often in play

Section 68 Section 143(3)Section 115BBE Section 142(1)Section 69A Section 69 Section 143(2)Section 144

Issues it is cited on

section 106 section 66 creditworthiness of the creditor onus of proof paper company source of source share capital and share premium section 251(2)section 31 addition u/s 68 live link section 251(1)(a)

Judgments citing Govindarajulu Mudaliar v. CIT

Dinesh Kumar Soni, Jaipur vs. DCIT Cen Cir 1 Jaipur, Jaipur

In the result appeal filed by the assessee is allowed

ITA 863/JPR/2024[2017-18]Status: DisposedITAT Jaipur27 Sept 2024AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Pawan Kumar Garg (C.A.)For Respondent: Smt. Monisha Choudhary (Addl.CIT) a

Section 142(1)Section 143(2)Section 143(3)Section 44ASection 68Section 69C

…a credit entry in his books, and it is held that the relevant amount is the income of the assesse, it is not necessary for the department to locate its exact source - CIT v. M.Ganapathi Mudaliar [1964] 53 ITR 623 (SC), A. Govindarajulu Mudaliar v. CIT [1958] 34 ITR 807 (SC). (viii) The Hon'ble Supreme Court in the case of Sreelekha Banerjee v. CIT [1963] 49 ITR 112 has observed as under: 7 Sh. Dinesh Kumar Soni vs. DCIT "If there is an entry in the account books of the assessee which shows the receipt of a sum on conversion of high denomination notes tendered for conversion by the assessee himself, it is neces…

The Trivandrum Employees Co-Operative Society Limited No. 43, Thiruvananthapuram vs. The Income Tax Officer, Thiruvananthapuram

ITA 863/COCH/2023[2017-18]Status: DisposedITAT Cochin25 Sept 2024AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Shri R. Krishnan, CA

Section 115BSection 144BSection 250Section 40A(3)Section 68Section 80Section 80PSection 80P(2)Section 80P(2)(d)

…IN THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH, COCHIN Before Shri Satbeer Singh Godara, Judicial Member and Shri Amarjit Singh, Judicial Member ITA Nos. 863 & 792/Coch/2023 (Assessment Years: 2017-18 & 2018-19) The Trivandrum Employees Co-operative Society Ltd. The Income Tax Officer TC-26/1651, Nr. Bank vs. Ward-2(1), Employees Hall Trivandrum Thiruvananthapuram 695001 [PAN: AAAAT3713A] (Respondent) (Appellant) Appellant by: Shri R. Krishnan, CA Respondent Shri Sanjit Kumar Das, CIT- by: DR Date of Hearing: 13.08.2024 Date of 25.09.2024 Pronouncement: O R D E R Per Bench These assessee’s twin appeals ari…

The Trivandrum Employees Co-Operative Society Limited No. 43, Trivandrum vs. The Additional Joint Deputy Assistant Commissioner of Income Tax, Kochi

ITA 792/COCH/2023[2018-19]Status: DisposedITAT Cochin25 Sept 2024AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Shri R. Krishnan, CA

Section 115BSection 144BSection 250Section 40A(3)Section 68Section 80Section 80PSection 80P(2)Section 80P(2)(d)

Venkateshwara Wires Pvt. Ltd., Jaipur vs. Assistant Commissioner of Income Tax, Jaipur

In the result, the appeal of the assessee is allowed

ITA 322/JPR/2024[2018-19]Status: DisposedITAT Jaipur09 Sept 2024AY 2018-19

Bench: The Ld. Ao As Well As Before The Ld. Cit(A) As The Documents Submitted Was Only In Support Of Confirmations & Other Documents Already Submitted & No New Documents Were Submitted. 2. The Assessee Craves Your Indulgence To Add Amend Or Alter All Or Any Grounds Of Appeal Before Or At The Time Of Hearing.”

For Appellant: Sh. S. L. Poddar, AdvFor Respondent: Sh. Anoop Singh, Addl. CIT

Section 133(6)Section 142(1)Section 143(3)Section 68Section 801ASection 80I

…n the following cases:- S.No. PARTICULARS 1 [2022] 139 taxmann.com 352 (Calcutta) HIGH COURT OF CALCUTTA Principal Commissioner of Income-tax v. Swati Bajaj 2 [1995] 80 Taxman 89 (SC) SUPREME COURT OF INDIA Sumati Dayal v. Commissioner of Income-tax 3 [1958] 34 ITR 807 (SC) SUPREME COURT OF INDIA A. GovindarajuluMudaliar v. Commissioner of Income-tax 4 [1971] 82 ITR 540 (SC) SUPREME COURT OF INDIA Commissioner of Income-tax v. Durga Prasad More [2007] 161 Taxman 169 (SC) SUPREME COURT OF INDIA Commissioner of Income-tax v. P. 5 Mohanakala 6 [1963] 50 ITR 1 (SC) SUPREME COURT OF INDIA Kale Khan Mohammad Hanif v.…

Surabhi Entertainment Private Limited ( Previously Known As Pearls Entertainment Private Limited), New Delhi vs. DCIT, Circle-24(2), New Delhi

In the result, this appeal stands dismissed on merit

ITA 9736/DEL/2019[2011-12]Status: DisposedITAT Delhi03 Sept 2024AY 2011-12

Bench: Shri Kul Bharat & Shri Avdhesh Kumar Mishra

Section 132Section 143(3)Section 147Section 148Section 234ASection 68

…icer and thereupon the Assessing Officer should form an opinion accepting or rejecting the explanation based upon appreciation of facts/materials and other attending circumstances. Section 68 of the Act was examined in A. Govindarajulu Mudaliar v. CIT, (1958) 34 ITR 807 (SC) observing that there were ample authorities for the proposition that where an assessee fails to prove satisfactorily the source and nature of certain amount of cash received during an accounting year, the Assessing Officer is entitled to draw Inference that the receipts are of an assessable nature. Whether explanation should be accepted or no…

Shobna Agarwal, Ajmer Road Jaipur vs. ACIT Circle-2, Jaipur

ITA 226/JPR/2024[2017-2018]Status: DisposedITAT Jaipur02 Sept 2024AY 2017-2018

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Sh. Vedant Agarwal, AdvFor Respondent: Sh. A. S. Nehra, Addl. CIT

Section 115BSection 142(1)Section 143(1)Section 143(2)Section 143(3)Section 68

…e of a credit entry in his books, and it is held that the relevant amount is the income of the assesse, it is not necessary for the department to locate its exact source-CIT v. M.GanapathiMudalior [1964] 53 ITR 623 (SC)/A. Govindarajulu Mudaliar v. CIT [1958] 34 ITR 807 (SC). 12 Shobna Agarwal vs ACIT-2, Jaipur In the case of Roshan Di Hatti v. Commissioner of Income-tax [1977] 107 ITR 938 (SC)[08-03-1977] it is held by the Hon'ble Supreme Court as under:- x x x x In the case of Kale Khan Mohammad Hanif v. Commissioner of Income-tax [1963] 50 ITR 1 (SC)[08-02-1963] it is held by the Hon'ble Supreme Court as und…

Winsher Vinimay Pvt. Ltd., Kolkata vs. ITO, Ward - 9(2), Kolkata

ITA 1393/KOL/2018[2012-13]Status: DisposedITAT Kolkata06 Aug 2024AY 2012-13

Bench: Shri Rajpal Yadav & Shri Rakesh Mishraassessment Year: 2012-13

For Appellant: N o n eFor Respondent: Shri Bibekananda Madhu, JCIT, Sr. DR

Section 131Section 143(2)Section 143(3)Section 250Section 68

…Pvt. Ltd. [2013] 30 Taxmann.com 292 (Delhi). The assessing officer relied upon the following judicial pronouncements for the applicability of section 68 and for the inference that the receipts are of assessable nature: i. Govindarajulu Mudaliar Vs. CIT [1958] 34 ITR 807 ii. CIT Vs. Davi Prasad Vishwanath Prasad [1969] 72 ITR 194 (SC) iii. Commissioner of Income Tax Vs. Independent Media (P.) Ltd. [2012] 25 taxmann.com 276 (Delhi). Accordingly, in the light of the facts of the case and the exposition of the legal position with regard to the identity and creditworthiness of the subscriber companies and the genuinen…

DCIT 13(3)(2), Mumbai vs. Tarmat Limited, Mumbai

In the result, the appeal is dismissed

ITA 3106/MUM/2024[2018-19]Status: DisposedITAT Mumbai01 Aug 2024AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri Ratnesh Nandan Sahayassessment Year: 2018-19 Dcit 13(3)(2), Tarmat Limited Room No. 229, Roman Tarmat Ltd., Aayakar Bhawan, General Vaidya Marg, M. K. Road, Goregaon East, Vs. Mumbai- 400020. Mumbai- 400063. Pan: Aaact1561G (Appellant) (Respondent)

For Appellant: Shri Jigar MehtaFor Respondent: Shri P. D. Chougule, (Addl. CIT), SR. D.R

Section 153Section 250Section 250(4)Section 68

…ir reply on dt.01.04.2021 and 06.04.2021 and thereby proved their 19 ITA No._3106/MUM/2024 Tarmat Limited; A. Y.2018-19 identity. Therefore, the said case law is not relevant in view of the facts of the present case. b) A. Govindarajulu Mudaliar v. CIT (1958 34 ITR 807 SC) The said case is in context of sec 147 of the Act for income escapement assessment. It was held that the where an assessee fails to prove satisfactorily the source and nature of certain amount of cash received during the accounting year, the Income-tax Officer is entitled to draw the inference that the receipt are of an assessable nature i.e.,…

M/S. Qns Castings Pvt. Ltd., Muzaffarnagar vs. ITO, Muzaffarnagar

In the result, the appeal of the assessee is dismissed

ITA 3554/DEL/2017[2012-13]Status: DisposedITAT Delhi26 Jul 2024AY 2012-13

Bench: Shri Kul Bharat & Shri Avdhesh Kumar Mishra

Section 133(6)Section 143(3)Section 250(4)Section 68

…ation money has not been explained then, there is no duty upon the AO to point out the source from which the money was received by the assessee. Reliance is put on the decision of the Hon'ble Apex Court in the case of A. Govindarajulju Mudaliaar v. CIT (1958) 34 ITR 807. 19. It is observed from the above that the above adverse finding has been made on the strengthen of enquiries conducted u/s 133(6) of the Act and by making independent analysis of the documents to arrive at the conclusion that the appellant has failed to prove identity, creditworthiness and genuineness in respect of credits of Rs.10.27 crore as d…

Smt. Priyanka Gutpa, Alwar vs. ACIT, Central Circle, Alwar

In the result, the appeal of the assessee is allowed

ITA 143/JPR/2024[2017-18]Status: DisposedITAT Jaipur22 Jul 2024AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. P. C. Parwal, CAFor Respondent: Sh. Arvind Kumar, CIT

Section 115BSection 127Section 132Section 139Section 142(1)Section 153CSection 68

…of a credit entry in his books, and it is held that the relevant amount is the income of the assesse, it is not necessary for the department to locate its exact source CIT v. M.Ganapathi Mudaliar [1964] 53 ITR 623(SC) / A Govindarajulu Mudaliar v. CIT [1958] 34 ITR 807 (SC). Accordingly, the Ground no. 1 of the Appeal is hereby dismissed. 10 Smt. Priyanka Gupta vs. ACIT 6. The last ground of appeal is that the appellant craves right to add, alter or amend any of the grounds of appeal. 6.1 The appellant has not added or altered any of the above mentioned grounds of appeal. Accordingly such mention by the appell…

J C Home Tex, Jaipur vs. Assistant Commissioner of Income Tax Circle - 7, Jaipur

ITA 292/JPR/2024[2016-17]Status: DisposedITAT Jaipur10 Jul 2024AY 2016-17

For Appellant: Sh. Tarun Mittal, CA &For Respondent: Sh. Anoop Singh (Addl. CIT)

Section 133ASection 142(1)Section 143(1)Section 143(2)Section 143(3)Section 145(3)

…taxation under the provisions of the Act. In the absence of such proof, the revenue is entitled to treat it as taxable income. This was laid down as far back as 1958 when this court pointed out in A. Govindarajulu Mudaliar v. Commisioner of Income-tax [1958] 34 ITR 807, 810 (SC) that: "There is ample authority for the position that where an assessee fails to prove satisfactorily the source and nature of certain amount of cash received during the accounting year, the Income-tax Officer is entitled to draw the inference that the receipts are of an assessable nature." In the case of Kale Khan Mohammad Hanif v. Comm…

Gargi Global Academy Sansthan, Sikar vs. DCIT, Central Circle-2, Jaipur

In the result, both appeals of the assessee are partly allowed

ITA 260/JPR/2024[2016-17]Status: DisposedITAT Jaipur05 Jul 2024AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. P. C. Parwal (CA)For Respondent: Sh. Anil Dhaka (CIT)

Section 115BSection 127Section 132Section 133ASection 142(1)Section 143(2)Section 143(3)Section 153CSection 69

…of a credit entry in his books, and it is held that the relevant amount is the income of the assesse, it is not necessary for the department to locate its exact source CIT v. M.Ganapathi Mudaliar [1964] 53 ITR 623 (SC) / A Govindarajulu Mudaliar v. CIT [1958] 34 ITR 807 (SC) and similar legal principle is applicable to the present facts of the case pertaining to source of unexplained investment. Since the income owned up by the two individuals in the settlement proceedings are on account of receipt of fees by them and not on account of impugned cash payment in land and rather the impugned cash payment for the la…

Vivekanda Shiksha Samiti, Palwas Road, Sikar vs. DCIT, Central Circle-2, Jaipur

In the result, both appeals of the assessee are partly allowed

ITA 203/JPR/2024[2017-18]Status: DisposedITAT Jaipur05 Jul 2024AY 2017-18

For Appellant: Sh. P. C. Parwal (CA)For Respondent: Sh. Anil Dhaka (CIT)

Section 115BSection 127Section 132Section 133ASection 142(1)Section 143(2)Section 143(3)Section 153CSection 69

…of a credit entry in his books, and it is held that the relevant amount is the income of the assesse, it is not necessary for the department to locate its exact source CIT v. M.Ganapathi Mudaliar [1964] 53 ITR 623 (SC) / A Govindarajulu Mudaliar v. CIT [1958] 34 ITR 807 (SC) and similar legal principle is applicable to the present facts of the case pertaining to source of unexplained investment. Since the income owned up by the two individuals in the settlement proceedings are on account of receipt of fees by them and not on account of impugned cash payment in land and rather the impugned cash payment for the lan…

ITO, Ward-24(1), New Delhi vs. Sun Intrastate Pvt. Ltd., New Delhi

In the result, the appeals of the Revenue are dismissed

ITA 1470/DEL/2023[2018-19]Status: DisposedITAT Delhi02 Jul 2024AY 2018-19

Bench: Sh. Kul Bharatdr. B. R. R. Kumar

For Appellant: Sh. Gautam Jain, Adv. &For Respondent: Ms. Deepti Chandola, Sr. DR

Section 131Section 133(6)Section 142(1)Section 147Section 148Section 68

…ct demands that assessee has to provide an explanation to any sum credited in the accounts of the assessee and the said explanation should satisfy the Assessing Officer of the sum credited in the books. In the case of A. Govindarajulu Mudaliar vs. CIT [1958] 34 ITR 807, it was observed by the Supreme Court that there is ample authority for the position that where an assessee fails to prove satisfactorily the source and nature of certain amounts of cash received during the accounting year, the Income-tax Officer is entitled to draw the inference that the receipts are of an assessable nature. In the case of CIT V…

ITO, Ward-24(1), New Delhi vs. Sun Intrastate Pvt. Ltd., New Delhi

In the result, the appeals of the Revenue are dismissed

ITA 1469/DEL/2023[2016-17]Status: DisposedITAT Delhi02 Jul 2024AY 2016-17

Bench: Sh. Kul Bharatdr. B. R. R. Kumar

For Appellant: Sh. Gautam Jain, Adv. &For Respondent: Ms. Deepti Chandola, Sr. DR

Section 131Section 133(6)Section 142(1)Section 147Section 148Section 68

Shobha Tomar, Jaipur vs. DCIT, C.C.1, Jaipur

In the result, the appeal of the assessee is allowed

ITA 373/JPR/2024[A.Y. 2017-18]Status: DisposedITAT Jaipur01 Jul 2024

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri G. M. Mehta, CAFor Respondent: Shri Anoop Singh, Addl. CIT

Section 115BSection 143(2)Section 143(3)Section 145(3)Section 44ASection 68

…able. To drive whom to this contention, he has relied upon the case laws cited in the order of ld. CIT(A) and also following case laws:- S.No PARTICULARS . 1 [1995] 80 Taxman 89 (SC) SUPREME COURT OF INDIA Sumati Dayal v. Commissioner of Income-tax 2 [1958] 34 ITR 807 (SC) SUPREME COURT OF INDIA A. GovindarajuluMudaliar v. Commissioner of Income-tax 3 [1971] 82 ITR 540 (SC) SUPREME COURT OF INDIA Commissioner of Income-tax v. Durga Prasad More 4 [2007] 161 Taxman 169 (SC) SUPREME COURT OF INDIA Commissioner of Income-tax v. P. Mohanakala 5 [1963] 50 ITR 1 (SC) SUPREME COURT OF INDIA Kale Khan Mohammad Hanif v.…

Amarpadma Credits Private Limited, Jodhpur vs. The Income Tax Officer, Ward-1(1)(1), Ahmedabad

In the result, the appeal of the assessee is partly allowed for statistical purposes

ITA 1/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad22 May 2024AY 2017-18

Bench: MRS. ANNAPURNA GUPTA (Accountant Member), SHRI SIDDHARTHA NAUTIYAL (Judicial Member)

For Appellant: Shri Gautam Baid, CAFor Respondent: Shri Ankit Jain, Sr. DR

Section 133Section 250Section 40A(3)Section 68

…as, it was exempt from taxation under the provisions of the Act. In the absence of such proof, the Income-tax Officer is entitled to treat it as taxable income". Similar finding was given by the Apex Court in case of A. Govindarajulu Mudaliar vs. CIT - [1958] 34 ITR 807 (SC).It was only later that the above dictum of the Apex Court found embodiment in section 68 of the Act. Background of section 68 Section 68 does not need any introduction. To summarise, it taxes any credit appearing in the books of an assessee, where the assessee is not able to or not satisfactorily able to explain the nature and source of such…

Balgopal Merchants Pvt Ltd vs. Principal Commissioner of Income Tax 2 Kolkata

Accordingly, the appeal fails and is dismissed

ITAT/232/2023HC Calcutta13 May 2024

Bench: THE HON'BLE THE CHIEF JUSTICE T.S SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

Section 131Section 143(1)Section 143(2)Section 260A

…ence that the receipts are of an assessable nature. 19. In Yadu Hari Dalmia Versus Commissioner of Income Tax 5 it was held that several Sections starting from Section 68 have been 4 (1958) 34 ITR 807 5 (1980) 126 ITR 48 ITAT NO. 232 OF 2023 REPORTABLE Page 12 of 26 introduced into the taxing enactments step by step in order to plug loopholes and in order to place certain situations beyond doubt even though there were judicial decisions covering some of the aspects. Even long prior to introduction of Section 68 in the statute…

M/S Satwant Agro Engineers, Bhawanigarh vs. DCIT, Central Circle, Patiala

In the result, the appeal of the assessee is partly allowed for statistical purposes

ITA 753/CHANDI/2022[AY 2019-20]Status: DisposedITAT Chandigarh03 May 2024

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Deepak Anand, AdvocateFor Respondent: Shri Dharamvir, JCIT, Sr. DR

Section 115BSection 133ASection 143(2)Section 143(3)Section 68Section 69Section 69A

…me of the assessee and no further burden lies n the revenue to show that the income is from any particular source. It has further been held by the Hon'ble Supreme Court in CIT vs. M Ganpati Mudaliar [1964] 53 ITR 623 and A Govindrajulu Mudaliar vs. CIT [1958] 34 ITR 807 that "when the assessee has failed to prove satisfactorily the source and nature of the credit entry in his books and it is held that the relevant amount is income of the assessee, it is not necessary for the department to locate its exact source." The above observations also get support from the decision of Hon'ble ITAT Cochin Bench, Cochin in th…

Quest Online, Kolkata vs. ITO, Ward-49(1), Kolkata.

In the result, the appeal of the assessee is allowed

ITA 1046/KOL/2023[2020-21`]Status: DisposedITAT Kolkata03 May 2024

Bench: Shri Sanjay Garg & Rajesh Kumari.T.A. No.1046/Kol/2023 Assessment Year: 2020-21 Quest Online…………………………………...............................……….……Appellant Block-A, 3Rd Floor, Room No.24, 1, Chandni Chowk Street, Princep Street, Kolkata – 700072. [Pan:Aaafq4820G] Vs. Ito, Ward-49(1),Kolkata.............…..….…..….........……........……...…..…..Respondent Appearances By: Shri S. M. Surana, Advocate & Sunil Surana, Ca, Appeared On Behalf Of The Appellant. Shri S. Datta, Cit, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : May 02, 2024 Date Of Pronouncing The Order : May 03, 2024 Order Per Rajesh Kumar: The Present Appeal Filed By The Assessee For The Assessment Year 2020-21Against The Order Dated 08.09.2023 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. The Only Issue Raised In The Various Grounds Of Appeals Is Against The Confirmation Of Addition By Cit(A) Of Rs.14,82,41,932/- As Made By The Assessing Officer U/S 68 Of The Act R.W.S. 115Bbe Of The Act. 3. The Facts In Brief Are That The Assessee Filed Return Of Income On 09.01.2021 Declaring Total Income From Business & Profession At Rs.36,73,790/-. The Case Was Selected For Complete Scrutiny Under Cass & Statutory Notices Were Duly Issued & Served Upon The Assessee. During The Assessment Proceedings, The Various Documents & Evidences Were Called For By The Assessing Officer From The Assessee

Section 115BSection 133(6)Section 143(3)Section 250Section 68

…transactions with the appellant. In fact, the Assessing Officer has found that Mr. Raja Sharma (Rudra Industries) is a car driver and Mr. Parimal Dey (Siddhi Trading Mfg. Co.) is a jute mill worker. 6.2.2 In the case of A.Govindarajulu Mudaliar v. CIT [1958] 34 ITR 807 (SC), the Hon'ble Supreme Court has held that the burden is on the assessee to prove or explain the source of the money or investment. Where an assessee fails to prove satisfactorily the source and nature of the investment, the Income Tax Officer is entitled to draw an inference that the amount is of an assessable nature. The relevant portion of t…