Taxpayer Fraud Allegations: Revenue Must Prove Intent u/s 271(1)(c) for False Depreciation Claims.

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....Penalty u/s 271(1)(c) - defraud by making false depreciation claim - The burden of proving the guilty animus on the part of the assessee is on the Revenue, like on Prosecution in criminal cases and no such negative burden could be cast upon by the assessee himself.....