KISHINCHAND CHELLARAM vs THE COMMR. OF INCOME-TAX BOMBAY CITY II, BOMBAY

The Supreme Court held that the Revenue failed to provide material evidence to support the finding that the amount of Rs. 1,07,350 represented concealed income of the assessee. The Court emphasized that the burden of proof lay with the Revenue to demonstrate that the remittance was made on behalf of the assessee, which they did not accomplish. The appeal was allowed, overturning the Tribunal's decision, as the evidence presented was deemed unreasonable and perverse, lacking a legitimate basis for the conclusion reached.