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Commissioner Of Income Tax West Bengal vs Anwar Ali on 29 April, 1970

35. To conclude on this aspect, it must be held that the patent intent of the Legislature in amending Section 271(1)(c) and omitting the word "deliberately" therefrom and inserting the Explanation thereto by the Finance Act of 1964 was to bring about a change in the existing law. Consequently, the ratio of Anwar Ali's case, which had considered the earlier provisions of Section 28(1)(c) (1922 Act) is no longer attracted to the situation. The principal logical import of the Explanation is to shift the burden of proof from the Revenue on to the shoulders of the assessee in the class of cases where the returned income was less than 80 per cent. of the income assessed by the Department. In this category of cases, the Explanation raises three rebuttable presumptions against the assessee as spelt out in detail above in paragraph 14 (supra p. 302) of this judgment. The onus of proof for rebutting the presumptions lies squarely on the assessee. This burden, however, can be discharged (as in civil cases) by the preponderance of evidence. Equally it may not be inflexibly necessary to lead fresh evidence and it would be permissible in the penalty proceedings for the assessee to show and prove that on the existing material itself, the presumptions raised by the Explanation stand rebutted.
Supreme Court of India Cites 13 - Cited by 577 - A N Grover - Full Document
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