https://www.taxtmi.com/caselaws?id=49515 An assessee's explanation for a receipt may be rejected by examining surrounding circumstances, including inconsistencies in the explanation and the absence of supporting evidence; if those circumstances justify only one proper inference, the receipt may be treated as income as a matter of fact. No question of law arises merely because the Tribunal considered surrounding circumstances, so long as its reasoning does not rest on irrelevant material, conjecture, or prejudice. On the facts discussed, direct evidence from the Department was not required once the explanation failed and the circumstances supported the inference that the receipt was income. en-us Thu, 22 Sep 1960 00:00:00 +0530 Tue, 02 Sep 2014 10:46:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=49515 An assessee's explanation for a receipt may be rejected by examining surrounding circumstances, including inconsistencies in the explanation and the absence of supporting evidence; if those circumstances justify only one proper inference, the receipt may be treated as income as a matter of fact. No question of law arises merely because the Tribunal considered surrounding circumstances, so long as its reasoning does not rest on irrelevant material, conjecture, or prejudice. On the facts discussed, direct evidence from the Department was not required once the explanation failed and the circumstances supported the inference that the receipt was income. Case-Laws Income Tax Thu, 22 Sep 1960 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=49515