https://www.taxtmi.com/caselaws?id=11978 For an addition under s. 69B, the burden lies on the Revenue to establish, with cogent material, that the assessee's real investment exceeded what was recorded; shifting that burden to the assessee would impose an impossible obligation to prove a negative, consistent with SC in K.P. Varghese. The HC held that a counsel's statement in interim civil proceedings regarding total investment, without supporting evidence showing how the figure was computed or correlating it to actual consideration, was not conclusive proof of undisclosed investment. The Tribunal's deletion of the addition was thus a non-perverse factual finding, raising no substantial question of law; the Revenue's appeal was dismissed. en-us Tue, 28 Jan 2003 00:00:00 +0530 Fri, 26 Dec 2025 17:50:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=11978 For an addition under s. 69B, the burden lies on the Revenue to establish, with cogent material, that the assessee's real investment exceeded what was recorded; shifting that burden to the assessee would impose an impossible obligation to prove a negative, consistent with SC in K.P. Varghese. The HC held that a counsel's statement in interim civil proceedings regarding total investment, without supporting evidence showing how the figure was computed or correlating it to actual consideration, was not conclusive proof of undisclosed investment. The Tribunal's deletion of the addition was thus a non-perverse factual finding, raising no substantial question of law; the Revenue's appeal was dismissed. Case-Laws Income Tax Tue, 28 Jan 2003 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=11978