https://www.taxtmi.com/caselaws?id=178644 A best judgment assessment still requires the taxing authority to identify the material relied upon before treating an item as the assessee's income. Here, the notice only asked why the son's income should not be assessed as the assessee's own, but it did not disclose any basis for alleging that the son was a mere name-lender or benamidar. The addition order also lacked definite supporting material. The court held that special-knowledge and presumption principles did not justify the addition, because the assessee was not confronted with the material before any adverse inference was drawn. The addition was unsupported by evidence and was disallowed. en-us Mon, 04 Jun 1951 00:00:00 +0530 Wed, 10 Feb 2016 11:42:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=178644 A best judgment assessment still requires the taxing authority to identify the material relied upon before treating an item as the assessee's income. Here, the notice only asked why the son's income should not be assessed as the assessee's own, but it did not disclose any basis for alleging that the son was a mere name-lender or benamidar. The addition order also lacked definite supporting material. The court held that special-knowledge and presumption principles did not justify the addition, because the assessee was not confronted with the material before any adverse inference was drawn. The addition was unsupported by evidence and was disallowed. Case-Laws Income Tax Mon, 04 Jun 1951 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=178644