ROSHAN-DI-HATTI vs COMMISSIONER OF INCOME TAX

The Supreme Court addressed the applicability of Section 34(1)(a) of the Income Tax Act, 1922, concerning reassessment for escaped income. It established that the burden of proof lies on the assessee to demonstrate the source of income, and that the Income Tax Appellate Tribunal must act judicially and based on relevant materials. The Court held that the Tribunal's findings can be interfered with if they are not supported by any material evidence, thereby emphasizing the need for a proper assessment process.