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    <description>Convictions for tax evasion offences under the Income-tax Act require proof of the foundational documents and positive evidence of wilful concealment; an assessment based only on estimate or guesswork is insufficient where the seized notebooks and loose papers are not produced or proved. Vicarious criminal liability cannot be fastened on all partners of a firm unless the record shows that each was in charge of and responsible for the conduct of the business. On the stated facts, both the conviction and the prosecution of all partners were found unsustainable for want of adequate proof.</description>
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