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    <title>1994 (3) TMI 80 - BOMBAY High Court</title>
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    <description>A remittance received by an intermediary for onward transmission cannot be taxed as the intermediary&#039;s income where the source is disclosed, the stated purpose is payment to a third party, and no material shows that any part remained with the intermediary. The Revenue bears the burden of proving that a receipt falls within the taxing provision, and an adverse inference cannot be drawn merely because the money passed through the assessee&#039;s hands. On these facts, the court found the Tribunal&#039;s conclusion unsustainable because it ignored the admitted source of the funds and the absence of evidence that the amount accrued to the assessee as his own income.</description>
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    <pubDate>Tue, 22 Mar 1994 00:00:00 +0530</pubDate>
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      <title>1994 (3) TMI 80 - BOMBAY High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=20197</link>
      <description>A remittance received by an intermediary for onward transmission cannot be taxed as the intermediary&#039;s income where the source is disclosed, the stated purpose is payment to a third party, and no material shows that any part remained with the intermediary. The Revenue bears the burden of proving that a receipt falls within the taxing provision, and an adverse inference cannot be drawn merely because the money passed through the assessee&#039;s hands. On these facts, the court found the Tribunal&#039;s conclusion unsustainable because it ignored the admitted source of the funds and the absence of evidence that the amount accrued to the assessee as his own income.</description>
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      <pubDate>Tue, 22 Mar 1994 00:00:00 +0530</pubDate>
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