1. In this case the assessee is the Managing Director of a private limited company doing Automobile business, in which his joint family had a controlling interest.

The assessee has been taxed as an individual for the assessment year 1946-47. The accounting year corresponds to the period from 1-4-1945 to 31-3-1946 and for this accounting year the assessee made a return of income showing Rs. 16,661 as salary and Rs. 3000 as dividend.

It appears that on 26-1-1946 the assessee encashed 78 high denomination notes of the value of Rs. 1000 each. In the declaration which is required to be made under the Ordinance the assessee said that the amount was his personal saving kept in the safe custody of the Ruler of Sakti State when there was panic in the year 1942 and there was danger of bombing of Jamshedpore.

Before the Income-tax Officer the assessee produced a certificate from the Ruler of Sakti dated 2-4-1947. The certificate was to the following effect

"With reference to your letter enclosing & request for a certificate for Mr. S.M. Patnaik, Income-tax Officer, Chaibasa, regarding the amount of Rs. 73,000 deposited by you with me in the year 1942 in my personal keeping, I have ple