Judgment

RAMASWAMI, J. : The appellant was carrying on business in jewellery, copper wire and money lending. The books of accounts of the appellant were closed on the 30th of June every year. For the assessment year 1951-52 (for which the previous year ended on .30th June 1950) the appellant did not comply with the notice issued under S. 22 (2) or S. 22 (4) of the Incometax Act. No return was filed by the appellant. The assessment was completed by the Income-tax Officer on such material as was available on the 23rd February 1955 and the income was assessed at Rs. 36,068. Subsequently, while making assessment for the assessment year 1955-56, the appellant had made investments for Rs. 39,000 during the previous year on the 30th June 1954. From the wealth statement it was found that the appellant had made investments for Rupees 39,000 during, the previous year which ended on the 30th June 1950, though in respect of that previous year, the appellant s income was assessed only at Rs. 36,068. A scrutiny of the wealth statement and the Bank account and the extensive nature of the business carried on by the appellant led the Income-tax Officer to entertain a belief that the income of the ye