JUDGMENT :

The Judgment of the Court was delivered by

S.K. Das, J.

1. This is an appeal by special leave. The appellant is the widow of one Kanji Jadhavji. Kanji Jadhavji had extensive businesses such as stevedoring, coal hauling, freight brokerage, clearing and forwarding of goods, loading and unloading of steamers, chartering of steamers etc. These businesses the widow inherited on the death of her husband. For Assessment Year 1947-48, the relevant accounting year being the calendar year 1946, the appellant was assessed en a total income of Rs 3,69,371, which was subsequently reduced to Rs 2,99,471 by the Appellate Assistant Commissioner. While assessing the appellant, the Income Tax Officer concerned added a sum of Rs 1,38,000 being the amount, of certain high denomination notes encashed by the appellant, as income from undisclosed sources. Being aggrieved by this addition, the appellant appealed to the Appellate Assistant Commissioner. The Appellate Assistant. Commissioner asked the Income Tax Officer to prepare from the records in the possession of the department statements of income returned and income assessed in the hands of the appellant for the years 1931 to 1945. These sta