( 1 ) THIS reference under the I. T. Act, 1961, arises out of the assessment of Mst. Zulekha Begum (Khatoon), the assessee, in the assessment year 1963-64, for which the relevant previous year was the financial year 1962-63.

( 2 ) THE facts found and/or admitted in the proceedings are as follows : On September 14, 1964, the assessee filed her voluntary return for the relevant assessment year showing an income of Rs. 10,294. Pursuant thereto, the ITO issued to the assessee a notice under Section 143 (2) of the Act. Thereafter, on September 7, 1967, the assessee filed another return, stated to be a revised return in respect of the same assessment year, showing an income of Rs. 18,429. The income was shown to have been derived from house property and leasehold property. The assessee contended that on April 18, 1962, she had purchased both the ownership as also a perpetual leasehold right in respect of the permises Nos. 21 and 22, Colootola Street, Calcutta, for a total consideration of Rs. 80,000. The ownership right was acquired for a consideration of Rs. 25,000 and the perpetual leasehold right was acquired for Rs. 55,000. The source of this consideration was s