https://www.taxtmi.com/caselaws?id=239336 A seized note, read with allied material, was treated as reliable evidence for invoking sections 69 and 69A of the Income-tax Act, 1961, with section 292C raising a presumption that shifted the initial burden to the assessee to explain the nature and source of the payment. The explanation offered was found insufficient to rebut that presumption, and objections based on lack of direct interest, absence of means, and non-supply of material did not dislodge the inference on the facts. However, because the assessee was seriously ill and a meaningful opportunity had to be given to the legal heirs, the matter was restored to the Assessing Officer for fresh adjudication rather than finally decided on merits. en-us Fri, 22 Feb 2013 00:00:00 +0530 Tue, 12 Nov 2013 06:09:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=239336 A seized note, read with allied material, was treated as reliable evidence for invoking sections 69 and 69A of the Income-tax Act, 1961, with section 292C raising a presumption that shifted the initial burden to the assessee to explain the nature and source of the payment. The explanation offered was found insufficient to rebut that presumption, and objections based on lack of direct interest, absence of means, and non-supply of material did not dislodge the inference on the facts. However, because the assessee was seriously ill and a meaningful opportunity had to be given to the legal heirs, the matter was restored to the Assessing Officer for fresh adjudication rather than finally decided on merits. Case-Laws Income Tax Fri, 22 Feb 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=239336