Messrs Mehta Parikh & Co vs The Commissioner Of Income-Tax,Bombay on 10 May, 1956
No other material has been mentioned by the Tribunal in their appellate judgment or in the statement of the case. It further appears that the Tribunal, in holding that seven high denomination currency notes of the value of Rs. 7,000 only could form part of the cash balance and the remaining currency notes could not do so, were acting on their surmises for which there was no basis and which had no support from any material on the record. In these circumstances, it must be held that there was no material for holding that the sum of Rs. 25,000 being the value of high denomination currency notes exchanged in pursuance of the High Denomination Bank Notes (Demonetisation) Ordinance, 1946, represented income of the assessee company from some undisclosed sources. This view of ours is in line with the decision of the Supreme Court in Mehta Parikh & Co. v. Commissioner of Income-tax, Bombay, in which case their Lordships of the Supreme Court also approved of a decision of the Patna High Court in Chunilal Ticamchand Coal Co. Ltd. v. Commissioner of Income-tax, Bihar and Orissa.