https://www.taxtmi.com/caselaws?id=8216 Remittances from Iran were not taxable in full without first proving a foreign source of income and the probable extent of accumulated profits from that source; the burden lay on the department to establish those facts before any rebuttable presumption could be applied, and the Tribunal erred by treating the assessee's failure to prove cash patrimony as enough. The Court also stated that a respondent in appeal may raise a pure question of law in support of the order under challenge, without fresh evidence, so the assessee could contest the validity of the section 34(1)(a) notice in the departmental appeal. Both points were answered in favour of the assessee. en-us Fri, 13 Feb 1970 00:00:00 +0530 Mon, 06 Apr 2009 09:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=8216 Remittances from Iran were not taxable in full without first proving a foreign source of income and the probable extent of accumulated profits from that source; the burden lay on the department to establish those facts before any rebuttable presumption could be applied, and the Tribunal erred by treating the assessee's failure to prove cash patrimony as enough. The Court also stated that a respondent in appeal may raise a pure question of law in support of the order under challenge, without fresh evidence, so the assessee could contest the validity of the section 34(1)(a) notice in the departmental appeal. Both points were answered in favour of the assessee. Case-Laws Income Tax Fri, 13 Feb 1970 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=8216