https://www.taxtmi.com/caselaws?id=22985 In penalty proceedings under section 271(1)(c) of the Income-tax Act, a factual finding that the assessee had discharged the onus under the Explanation, despite returned income being below the prescribed level, will not be disturbed in reference jurisdiction unless it is perverse or unsupported by evidence. The High Court found that the Tribunal's conclusion was supported by the record, even though its reasoning was not fully satisfactory, and therefore declined interference. The assessee's rebuttal of the presumption was upheld and the question was answered in favour of the assessee. en-us Tue, 13 Nov 1990 00:00:00 +0530 Tue, 15 Dec 2009 17:02:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=22985 In penalty proceedings under section 271(1)(c) of the Income-tax Act, a factual finding that the assessee had discharged the onus under the Explanation, despite returned income being below the prescribed level, will not be disturbed in reference jurisdiction unless it is perverse or unsupported by evidence. The High Court found that the Tribunal's conclusion was supported by the record, even though its reasoning was not fully satisfactory, and therefore declined interference. The assessee's rebuttal of the presumption was upheld and the question was answered in favour of the assessee. Case-Laws Income Tax Tue, 13 Nov 1990 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=22985