PARIMISETTI SEETHARAMAMMA vs COMMISSIONER OF INCOME-TAX, HYDERABAD

The Supreme Court held that under the Income-Tax Act, 1922, specifically Sections 3 and 4, the burden of proof regarding the taxability of receipts lies with the Department, not the assessee. The Court found that the gifts received by the appellant from the Maharani of Baroda were made out of natural love and affection and should not be treated as taxable income. The High Court's ruling that the appellant needed to prove the nature of the receipts was incorrect, leading to the reversal of the lower court's decision.