It is true that by reason of the settlement made under the Taxation on Income (Investigation Commission) Act, 1947 the assessee companies must be taken to have admitted that they had made secret profits which were kept out of the books of accounts and it is also true that no explanation was forthcoming from the assessee companies as to what became of such 47 secret profits but the question is whether from such absence of explanation any presumption can be raised that such secret profits were still retained by them on the valuation date in the circumstances of the case ? In the first place the analogy of the rule applicable in income tax cases would be inapplicable in wealth tax cases inasmuch as in the former case the unexplained cash credit item is regarded as income of the assessee from undisclosed source having accrued to him during the accounting year while in the latter case only the valuation date is relevant on which date the assets (secret profits) must be held by the assessee and it will not do that such asset was held by him some time during the concerned year.