Tax liability of Assessee cannot be assessed on Presumption

Baldev Raj Chhabra Vs ITO (ITAT Delhi)

ITAT find that both AO & CIT (A) have acted upon, only on the presumption and without any substantive material for making and sustaining the addition under consideration. In our considered view the presumption cannot be real adjudication of an issue. The very purpose of income tax proceedings is to correctly assess the tax liability of an Assessee in accordance with law but not under presumption as held in this case. Article 265 of the Constitution of India prescribes that no tax sh

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