( 1 ) THIS reference under Section 66 (1) of the Indian I. T. Act, 1922, arises out of the income-tax assessment of Ananda Bazar Patrika Private Ltd. , the assessee, for the assessment year 1953-54, the relevant previous year being the calendar year 1952.

( 2 ) THE assessee is engaged in the publication and sale of various newspapers and periodicals. The ITO computed the taxable income as follows : Loss of Rs. 4,951 under the head "business" ; income of Rs. 31,335 under the head "income from property" and an income of Rs. 1,85,963 under the head "other sources". The last item was arrived at by including a sum of Rs. 1,63,000 from a credit of Rs. 2,50,000 standing in the account of Sarala Bala Sarkar, the grandmother of the managing director of the assessee, which the ITO treated as the assessee's income from undisclosed sources.

( 3 ) ON appeal, the AAC, on the basis of certain data relating to circulation figures of the publications of the assessee as supplied to the Audit Bureau of Circulation, held that business income of Rs. 6,92,771 had not been accounted for in the books of the assessee. He held further that the said sum of Rs. 1,63,000 added as income from und