, J.

1. For the assessment year 1946-47 the petitioner was assessed under Section 23(3), Income-tax Act, upon the total income of Rs. 32,689/-. After the assessment was completed the Income-tax Officer received information that on 19-1-1946, the petitioner had encashed high denomination notes to the extent of Rs. 28,000/-. Proceedings were thereupon initiated under Sec.34, Income-tax. Act. The assessee filed a fresh return and gave explanation that the amount of Rs. 28,000.00 represented the amount of savings accumulated from his personal income upon which income-tax had already been paid. In his letter dated 16-6-1947 the assessee states:

"The funds of the high denomination notes accumulated from savings of my personal income since the date of our disruption of joint Hindu family. There was a run in the bank when England was off gold standard; since then we were in the habit of keeping some reserve cash at home in order to meet the personal and business needs. The high denomination notes in question form part of this reserve cash."

The Income-tax Officer did not accept the explanation and included the entire amount of Rs. 28,000.00 as secreted profits of the assessee durin