Dcit, Jaipur vs Godawari Estates Pvt. Ltd., on 7 November, 2017
viii) The assessing officer merely disbelieved the explanation/statements given by
the assessee and has converted good proof into no proof. Hon'ble Justice
Hidayatullah of the Supreme Court in the case of Sreelekha Banerjee Vs CIT
[1963] 49 ITR 112 (SC); 120 observed that the Income Tax Department cannot by
merely rejecting unreasonably a good explanation, convert good "proof into no
proof"