Burden of proof for tax liability deductions requires evidence that the claimed liabilities were legally payable.

A deduction for claimed income-tax and wealth-tax liabilities is not allowable unless the assessee proves that the liabilities were legally payable and supported by evidence. Where the assessee failed to produce material establishing the alleged liabilities, the burden of proof was not discharged, and the claim was disallowed in favour of the Revenue.

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Issues: Whether the assessee was entitled to deduction of the claimed income-tax and wealth-tax liabilities for the relevant assessment years.

Analysis: The liabilities claimed by the assessee were disallowed for want of evidence establishing that they were legally payable by the assessee. The authorities found that the assessee had not produced material to prove the alleged liabilities, and the burden to establish entitlement to the deduction lay on the assessee. A party asserting a deduction or liability discharge must prove the fact, especially when the relevant facts are within that party's knowledge.

Conclusion: The question was answered against the assessee and in favour of the Revenue; the claimed deductions were not allowable.

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