R.N.MITTAL and P.C.PANDIT JJ.

1. The facts of the present reference are as follows : The assessee is a registered firm and derives income from arhat and karyana business. It has five partners, namely, Dharam Chand, Sat Parkash, Ram Naranjan, Ved Parkash and Nand Lal. The share of Dharam Chand, who is the father of the other partners, is four annas and that of Sat Parkash and other is three annas each. The Income-tax Officer, while examining the account books making an assessment for the assessment year 1954-55, found cash credits totalling to Rs. 47,996 to the credit of four ladies as detailed below Sl. No.AmountDate Name

(1) Rs. 11,980 16-7-1953Smt. Shanti Devi, wife of Shri Ved Parkash, partner.

(2) Rs. 11,980 17-7-1953Smt. Raj Rani, wife of Shri Nand Lal, partner.

(3) Rs. 11,980 30-12-1953Smt. Lajjya Wanti, wife of Shri Ram Naranjan, partner.

(4) Rs. 11,980 22-1-1954Smt. Suhag Wanti, wife of Sat Parkash, partner.

2. The explanation given by the assessee was that Bhagwanti Devi, wife of Dharam Chand, died on April 12, 1953. After her death, her almirahs and trunks were ransacked and jewellery, gold and cash in addition to her wearing apparel were found. They were distribu