The Income tax officer, therefore, had reasons to believe that income to the extent of Rs. 43,116/ had been under assessed and he issued notice under section, 34." Thus in view of the findings given by the Income tax authorities the following facts emerge: (1) that at the time of the original assessment the appellant had filed his return claiming a deduction of Rs. 43,116/ and filed the balance sheet in support of his plea; (2) that the balance sheet showed that the capital of the firm was Rs. 8,70,000/ , total drawings by the partners stood at Rs. 29,31,998/ and the loans were Rs. 6,63,292/ The Income tax officer who completed the original assessment appears to have accepted the claim of the appellant because the balance sheet without any further scrutiny and a close calculation would not have revealed that the amount of deduction claimed was really in the nature of interest free loans given to the partners to meet their income tax liabilities: (3) that in 1958 59 the Income tax officer discovered that the deduction claimed by the appellant was not correct and he accordingly called upon it to prove its plea but the appellant led no evidence before the Income tax officer.