As per case facts, the assessee, an art dealer, declared substantial amounts as race winnings in her capital account over two assessment years. The tax authorities, however, treated these receipts ... as income from undisclosed sources and assessed them accordingly. The assessee challenged this, asserting the source was legitimate race winnings, even offering to accept a reasonable addition during appeal to the Settlement Commission. The majority of the Commission upheld the department's assessment, leading to this appeal. The central legal question was whether the appellant's explanation for these significant credits as race winnings was genuine, or if they constituted undisclosed income, considering the burden of proof and the authorities' right to investigate the reality behind apparent transactions. Finally, the Supreme Court upheld the majority opinion of the Settlement Commission. It concluded that the appellant's claim of winnings was not genuine, finding that the explanation was reasonably rejected and the determination of these amounts as income from other sources was based on evidence. The Court stressed the 'test of human probabilities,' noting the implausibility of continuous winnings, the appellant's limited racing knowledge, and insufficient records, suggesting the winning tickets were likely acquired post-event using unaccounted funds, especially in light of legislative changes to tax such winnings.