V.Ramaswami, J.

1. In this case the two assessees were equal partners in the firm of K.C. and P.C. Mukherjee of ijua. Assessments were originally made for the years 1945-46, 1946-47 and 1947-48 on the share income return of the two assessees. Later on it transpired that the two assessees had made substantial investments in two private limited companies. Mohalbanj Collieries Limited and Central Kankanee Collieries Limited, the amounts involved being Rs. 25,000.00 for the calendar year 1944, Rs. 55,348/-for the calendar year 1945 and Rs. 55,000.00 for the calendar year 1946, in each case. After having satisfied himself that income had escaped assessment the Income-tax Officer issued notices under Sec.34 on the 8th September, 1949, to both the assessees in respect of the three assessment years. The assessees made returns under Sec.34 and declared the following amounts of income each:

Rs. 1945-46...45,325...Share income 14,000...Other sources, cash introduced shown as income in the absence of proof. Total.... 59,325 1946-47...31,772...Share income 23,448 ...Other sources Total....55,220 1947-48...24,581...Share Income 55,000...Other sources, cash introduced shown as income in a