Onus to prove that income falls under Exemption provisions Fully Lies on Taxpayer

Shamji Manekji Shah Vs DCIT (ITAT Mumbai) The issue under consideration is whether the onus to prove the case which strictly falls under exemption provisions is fully on the taxpayer? In the present case, the assessee is seeking to claim exemption from income-tax on gains on sale of land on the grounds that land sold was an agricultural land used by the assessee for agricultural purposes and hence the onus is on the assessee to prove that its case fall strictly within conditions stipulated within taxing statute of 1961 for seeking exemption from income-tax before any claim for exemption can be...