‘Proof Beyond Reasonable Doubt’ Applies to Criminal Cases, Not Income Tax

PCIT-1 Vs East Delhi Leasing Pvt. Ltd. (Delhi High Court) Delhi High Court held that principle enunciated in the criminal jurisprudence in respect of a ‘proof beyond reasonable doubt’ was erroneously applied to section 148 of the Income Tax Act. Thus, order based on incorrect application of principle is liable to be quashed. Facts- The question of law involved in the present case is whether the ITAT was not wrong in applying the principles enunciated by the SC in a criminal case where the discharge of burden of proof is beyond reasonable doubt, to the principle of “reason to believe” a...