Sec.69A–Deeming provision cannot be initiated based on suspicion

Brief of the Case

Punjab & Haryana High Court held In the case of CIT vs. Shri Jawahar Lal Oswal & others that suspicion and doubt may be the starting point of an investigation but cannot, at the final stage of assessment, take the place of relevant facts, particularly where a deeming provision is sought to be invoked. The principle that governs a deeming provision is that the initial onus lies upon the revenue to raise a prima facie doubt on the basis of credible material. The onus, thereafter

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