Judgement

SHAH, J. : The appellant carried on business at Nuzvid as a moneylender and conducted a cinematograph theatre. In respect of income from property and business she submitted a return of her income for the assessment year 1947-48 and disclosed in a statement dated August 26, 1949 that Sita Devi Maharani of Baroda-had between November 10, 1045 and February 11, 1948 "out of natural love and affection given to her some jewellery and four amounts of money , which aggregated to Rs. 5,20,000. The Income-tax Officer, Special Circle, Vijayawada accepted the appellant s statement and did not treat the money and jewellery received by her as, taxable income. In the course of assessment proceedings for the year 1951-52 the Income-tax Officer was inclined to treat the money and jewellery given to the appellant as remuneration for services rendered to Sita Devi as a maid-servant. He accordingly issued a notice under S. 34 of the Income-tax Act and called upon the appellant to submit an explanation adducing all documentary and other evidence in her possession relating to the receipt of assets admitted by her in her statement" dated August 26, 1949 and relating to other cash amounts and c