https://www.taxtmi.com/caselaws?id=286339 The Tribunal held that the burden of proof rested on the Department to establish that cash credits were the assessee's income, ultimately canceling the penalty under section 271(1)(c). The Tribunal emphasized that penalty proceedings were distinct from assessment proceedings, allowing the assessee to rebut presumptions. The Court directed the Tribunal to refer a question of law for opinion, noting that the issue of cash credits as income had been resolved. The judgment focused on interpreting statutory provisions, burden of proof, and legal principles under the Income Tax Act, 1961. en-us Fri, 07 May 1982 00:00:00 +0530 Fri, 21 Feb 2020 15:00:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=286339 The Tribunal held that the burden of proof rested on the Department to establish that cash credits were the assessee's income, ultimately canceling the penalty under section 271(1)(c). The Tribunal emphasized that penalty proceedings were distinct from assessment proceedings, allowing the assessee to rebut presumptions. The Court directed the Tribunal to refer a question of law for opinion, noting that the issue of cash credits as income had been resolved. The judgment focused on interpreting statutory provisions, burden of proof, and legal principles under the Income Tax Act, 1961. Case-Laws Income Tax Fri, 07 May 1982 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=286339