AJIT K. SENGUPTA, J.

( 1 ) IN this reference under Section 256 (1) of the Income-tax Act, 1961, for the assessment year 1963-64, the following questions of law have been referred to this court :"1. Whether, on the facts and in the circumstances of the case, the Tribunal was right in law in upholding the action of the Income-tax Officer in initiating proceedings under Section 147 (a) of the Income-tax Act, 1961, for the assessment year 1963-64 ? 2. Whether, on the facts and in the circumstances of the case, the Tribunal was justified in sustaining the addition of the sum of Rs. 77,786 made by the Income-tax Officer as income of the assessee under the head 'other sources' for the assessment year 1963-64 ?"shortly stated, the facts are that the assessee-company started construction of a building in the accounting year 1960-61 and the construction was completed in the accounting year ending on March 31, 1966. The total cost incurred by the assessee on the construction of the building was considered during the assessment year 1966-67 and the Income-tax Officer was of the opinion that the cost disclosed by the assessee was lower than the cost actually incurred. Accordingly, the Income-t

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