DILIP N. SHROFF vs. JOINT COMMNR. OF INCOME TAX, MUMBAI &ANR
The appeal is allowed
C.A. No.-002746-002746 - 2007Supreme Court18 May 2007
For Respondent: Joint Commissioner of Income Tax, Mumbai & Anr
6\005It must be remembered that the proceedings under
Section 28 are of a penal nature and the burden is on the
Department to prove that a particular amount is a revenue
receipt. It would be perfectly legitimate to say that the
mere fact that the explanation of the assessee is false
does not necessarily give rise to the inference
