https://www.taxtmi.com/caselaws?id=5716 Conviction under ss. 276C and 277 of the Income-tax Act requires proof of a wilful attempt to evade tax and a knowingly false verification, i.e., established mens rea beyond reasonable doubt. The SC held that the statutory presumption under s. 132(4A) does not, by itself, satisfy these ingredients. Further, the Tribunal's categorical finding while deleting penalty under s. 271(1)(c) that the return was on estimate basis and the dispute was only a difference of opinion on estimates negated concealment or inaccurate particulars, reinforcing absence of the requisite mens rea. As the HC interfered with acquittal without examining the trial court's grounds and contrary to settled limits on appellate reversal, the HC's conviction was set aside and the acquittal restored. en-us Tue, 09 Feb 1999 00:00:00 +0530 Fri, 31 Jul 2026 16:34:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=5716 Conviction under ss. 276C and 277 of the Income-tax Act requires proof of a wilful attempt to evade tax and a knowingly false verification, i.e., established mens rea beyond reasonable doubt. The SC held that the statutory presumption under s. 132(4A) does not, by itself, satisfy these ingredients. Further, the Tribunal's categorical finding while deleting penalty under s. 271(1)(c) that the return was on estimate basis and the dispute was only a difference of opinion on estimates negated concealment or inaccurate particulars, reinforcing absence of the requisite mens rea. As the HC interfered with acquittal without examining the trial court's grounds and contrary to settled limits on appellate reversal, the HC's conviction was set aside and the acquittal restored. Case-Laws Income Tax Tue, 09 Feb 1999 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=5716