In Brief
The Commissioner of Income-Tax appealed against a High Court dismissal of its appeal challenging the Tribunal's and first appellate authority's decision that pronotes seized during a survey should be valued at 30% of face value (representing disclosed income) rather than full face value as undisclosed income. The Court held that the Department failed to produce contradictory evidence; borrowers had confirmed amounts advanced were 50% or less of pronote values. Since multiple family members jointly conducted business from the same premises, any concealed income discovered should be distributed among all family members engaged in the business. The appeal was dismissed."
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