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Section 143 of the Income-tax Act, 1961 - Assessment - Addition to income CASES REFERRED TO [1951] 19 ITR 191. JUDGMENT Srinivasachari, J.-These references have come before us on a direction by us to refer a question of law arising in the case under section 66(2) of the Indian Income-tax Act. The assessee is one Sitaramamma alias Manavathi Bai, resident of Nuzwid, West Godavari. She was assessed by the Income-tax Officer, Vijayawada, for the assessment year 1946-47. She was asked to submit a return and in the return that she submitted she showed a sum of Rs. 70,000 as gift received in cash from Princess Sita Devi, daughter of the Raja of Pithapuram, who was married to the Kumar Raja of Vuyyur and after divorce married to the ex-Gaekwad of Baroda. As the assessee did not file any documents or adduce any evidence in support of the version of the gift, the Income-tax Officer treated the receipts as salary and remuneration and as he found that the assessee had received valuable jewellery also from the said Sita Devi, he added the value of the jewellery also, viz., Rs. 4 lakhs, in computing the taxable income. The total taxable income according to him was Rs. 4,70,000 (Rs. 4 lakhs representing the value of the jewellery and Rs. 70,000 cash received from Sita Devi). The assessee went in appeal before the Appellate Assistant Commissioner and contended that the amounts were not salaries paid, and submitted that the various amounts received by her could be regarded only as "windfall". The Appellate Assistant Commissioner not being satisfied with the version put forward by the assessee and because the record before him showed that she had acted as the local agent of the said Sita Devi and it had also appeared that she was styled the private secretary of the said Sita Devi, he came to the conclusion that the amounts received by her were in lieu of services rendered to the said Sita Devi. In the result he affirmed the order of the Income-tax Officer with regard to the sum of Rs. 70,000 treating it as amount received by the assessee for services rendered. With regard to the value of the jewellery the jewels were got valued by a local firm of jewellers, Ummidi Ramiah Setti,…

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