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“Section 71(4)”
Section References (mined)Section 71Section 71(4)4 judgments
The decision most relied on for Section 71(4) is CIT v. Shivakami Co. (P.) Ltd. (159 ITR 71), cited in 133 judgments on BharatTax.
Leading authorities on Section 71(4)
CIT v. Shivakami Co. (P.) Ltd.
159 ITR 71 · 1986 · Supreme Court
133
citing judgments
The burden of proving an understatement of consideration or the receipt of 'on-money' lies solely with the Revenue, which must provide cogent evidence of actual receipt of higher consideration, beyond mere estimates or suspicion. Additions cannot be made based on assumptions like differences from circle rates without such evidence.
Para 71-75 ACIT v. Kences
308 ITR 230 · 2009 · High Court
47
citing judgments
Undisclosed income cannot be added based solely on seized documents or notings/jottings without corroborative or direct evidence that these materialized into transactions.
