Where assessee had only 50 per cent share in property since she and Section 5A of the IT Act speaks about division of income amongst the spouses and not division of assets. Once the substantive rights of the assessee were governed by section 5A of the Portuguese Civil Code, the mere non-mention of the same in the return of income would not make any difference. her late husband were governed by Portuguese Civil Code applicable to residents of Goa and sale consideration corresponding to her share had been duly offered in return of income, reopening notice issued under section 148 on ground that actual payment had not been disclosed in return of income and order rejecting objections deserved to be quashed and set aside.