https://www.taxtmi.com/caselaws?id=24301 Under the Explanation to section 271(1)(c) of the Income-tax Act, the initial presumption against the assessee is rebuttable, and on the facts the assessee successfully rebutted it by producing documentary evidence in penalty proceedings showing that the closing stock was later sold at comparable rates. The lower valuation used in the return had led to an addition in assessment, but the penalty could not be sustained once the surrounding evidence explained the valuation. The High Court held that imperfect wording in the Tribunal's observations did not affect the correctness of its factual conclusion, and the penalty was therefore not justified. en-us Tue, 15 Nov 1988 00:00:00 +0530 Tue, 19 Jan 2010 11:12:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=24301 Under the Explanation to section 271(1)(c) of the Income-tax Act, the initial presumption against the assessee is rebuttable, and on the facts the assessee successfully rebutted it by producing documentary evidence in penalty proceedings showing that the closing stock was later sold at comparable rates. The lower valuation used in the return had led to an addition in assessment, but the penalty could not be sustained once the surrounding evidence explained the valuation. The High Court held that imperfect wording in the Tribunal's observations did not affect the correctness of its factual conclusion, and the penalty was therefore not justified. Case-Laws Income Tax Tue, 15 Nov 1988 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=24301