1983 (8) TMI 1

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.... of the decision of this court in [1981] 130 ITR 244 (Jamnaprasad Kanhaiyalal's case). Counsel for the assessee, however, urged before us that two points arise for decision in this case and that the decision of this court in Jamnaprasad Kanhaiyalal's case does not cover both the points which have been decided by the High Court in favour of the assessee. We are unable to accept this contention, ....

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....nts which had been accepted by the Commissioner of Income-tax thereunder, the initial onus which lay under s. 68 of the 1961 Act on the assessee to offer a satisfactory explanation should be taken to have been discharged and the onus shifted thereafter on the ITO to establish that the sum so credited were the income of the assessee which had not been discharged and the High Court had taken the vie....