Grounds to corroborate of concealing income by respondent after putting false allegations on petitioner only to get unfair maintenance:

1.Because of, the learned court  relied only on the Net salary as per salary-slip bonafidely produced by the petitioner and passed the impugned order without looking into his liabilities towards his parents and other financial obligations. The learned court has not appreciated that petitioner has provided all the details bonafidely whereas respondent has hidden many facts and the legal maxim " falsus in uno, falsus in omnibus" says that false in one thing, false in everything ". A true person would always like to put everything authentically before law.

2. Because of, the learned court has failed to see that it is admitted fact that respondent is professionally qualified management post graduate (M.B.A) and she used to do work both time means before and after marriage and also having one joint account by showing TDS return in ITR which itself clears that she is earning at present. But learned court below wrongly concluded that the joint account belongs to his brother, however the first account holder is respondent and also comes under IT Act but learned court wrongly taken into consideration without looking into taxation laws.

It is to be mentioned here that the respondent in her initial application she has mentioned that she has no source of earning and that she is dependent on her mother and brother for her livelihood. However, the respondent did not approached the court with clean hands and has lied on oath. The same is explained below :

a.         While she was residing with Petioner Shived during the course of her marriage at her matrimonial home in Faridabad until 24.08.2018  ,she was yet involved in some kind of commercial business activity with her brother who happens to be an Income Tax Lawyer at Jabalpur . Before the learned court below Petitioner has produced respondent’s Axis Bank a/c-911010056397880- statement which shown an income tax refund of Rs 6290 against her PAN card no BCOPK5224K through an entry dated 26/09/2018 for the AY 2018 .The lower court has agreed that there are multiple entries seen in her account where different persons are depositing money in her Axis Bank account.

b.  In response to this finding by Petitioner, the respondent submitted her ITR to the tune of Rs 94000 for the AY 2018-19 and Rs 38440 for 2019-20. It is to be further mentioned here that the ITR for the Year 2019-20 was filed on dated 25.06.2019 which happens to be after our WS submission date of 7. 5. 2019 .In addition, respondent’s brother advocate brother Ankur Khare submitted an affidavit which says that the account of his sister Megha is being managed by him for his professional work. 

c. The affidavit has again been categorically tweaked to mislead the court once again. Mr. Ankur Khare has mentioned that his sister, respondent  is the Joint account holder (“संयुक्त खाता धारक” ) . In reality the respondent is the Primary account Holder and Ankur Khare is the secondary account holder .According to RBI and Banks , the responsibility and ownership of the nature and quantum of transactions is owned by the Primary account holder.

d. The nature of work of an Income Tax advocate –Mr.Ankur Khare- is to help his clients file Income Tax returns . There is no valid reason as to why an Income Tax advocate will ask his clients to deposit money into his sister’s personal savings bank account. Even if these incoming funds are considered to be his practicing fee then there should not be any outgoing funds, as can be seen from the bank statement .After all no lawyer will ever refund his fee back to his clients. These are certainly some business related transactions which are Megha’s income in reality. This declaration, in form of an affidavit by MrAnkur has been given to mislead the court so that respondent can stand firm on her original statement that she does not have a source of income and continues to be dependent on her mother and brother. This declaration from her Income Tax advocate brother ,Ankur is an attempt to conceal her income ,which was originally rebutted by Shived in his original WS  . This manipulation of fact has been ignored by the lower court. 

e. It is to be further noticed that the value of the ITR furnished by respondent on being happens to be Rs 94000 for the AY 2018-19 and Rs 38440 for 2019-20. This boils down to an average monthly income of Rs 7500 per month for AY 2018-19 and Rs 3100 for the AY2019-20 .This is yet another contradiction .Her Average monthly balance of the said Axis Bank account 911010056397880 is between Rs20000 to Rs 25,000 per month .In other words, the produced ITR is understated deliberately to conceal her actual income. This is a typical case of concealment of Income and qualifies for a TAX EVASION PETITION ,unless explained by Respondent in a justifiable and convincing manner ,which should be in concurrence with the prevailing Income Tax Act laws

f.  In the FY 2017 -18 , there have been deposits to the tune of Rs 574761 which means a monthly income of Rs 45000 /-. There are inward clearances of Rs 268461and cash deposits of Rs 306000 /-. It was pointed out before the learned court below that there was some kind of alleged involvement of Respondent with her Advocate brother Ankur Khare ,owing to which she travelled frequently to Jabalpur .This has also been acknowledged by the lower court and mentioned in the impugned order.

g. In an entry dated 08-05-2018 Ankur himself has deposited Rs 48000 in Respondent’s account. There is no valid reason given by the respondents as to why, it is being deposited his client’s money for cash in his sister’s account. In another entry dated 28.06.2017 there is a credit of Rs 25000 by Kanwar Enterprises . Likewise there are cash deposits by various people in the name of Arvind Kumar ( Rs 2900 and Rs 2300 on 16.01.2018) and Amit (Rs 44000 on 08.01.2018). Another entry of Rs 110000 by Indmac India Private Ltd on 11.3.2019 etc.This clearly shows some kind of commercial business activity going on between Respondent and her brother Ankur, who is an Income Tax advocate by Profession.

h. For the FY 2018 –2019 ,there have been deposits to the tune of Rs 379240 which indicates a monthly income of Rs 31600/-.

i. It is to be further noted that the deposits or inwards cheque clearances / IMPS have dried up after submission of original WS of May 7 2019  by Respondent  Shived . This again is a deliberate attempt by Respondent Megha to conceal her income.

j. Similarly in an entry dated 14-11-2018 in her ICICI Bank A/c no. 140001510406 she is getting Rs3000 credited as EXPENSES REIMBURSEMENT. Usually such entries are made by corporates while re-imbursing actual expenses incurred by the employees on the field or some outstation work assigned to them .

k. It is to be noted that this date of 14-11-2018 is after her final exit from her matrimonial home at Faridabad on 24-08-2018. This is strong pointer that Respondent is either working or is self-employed in some business activity.

l. Since it has been highlighted several instances of Bank statements across FY 2017-18 and FY 2018-19 of Respondent having a continuous source of income, but learned court below never asked for any explanation about each and every single entry showing credit of income in Respondent's account and the nature of business activity that she is involved in.

J. The learned court has erred to not consider that it is wrong to get unfair maintenance from petitioner by putting false allegations on petitioner.