“Section 91(4)”
The decision most relied on for Section 91(4) is Pullangode Rubber Produce Co. Ltd. v. State of Kerala (91 ITR 18), cited in 666 judgments on BharatTax.
Leading authorities on Section 91(4)
Admissions, whether made through entries in account books or statements, are important pieces of evidence but are not conclusive. An assessee has the right to demonstrate that an admission made by them is incorrect or can be retracted.
Income cannot be assessed on purely notional figures or mere suspicion; it must be based on actual evidence and supporting material demonstrating its accrual or receipt by the assessee. Assessments made without such evidence are bad-in-law.
Penalty under section 271(1)(c) cannot be levied when a substantial question of law is admitted by the High Court on an addition, indicating the issue was debatable and the assessee acted bona fide.
