COMMISSIONER OF INCOME-TAX, MADRAS vs K.R. SADAYAPPAN

The Supreme Court held that under Section 271(1)(c) of the Income Tax Act, 1961, the assessee is deemed to have concealed income if the total income returned is less than 80% of the assessed income, unless proven otherwise. The Court found that the High Court erred in not applying the principles from C.I.T. v. Mussadilal Ram Bharose, 165 ITR 14, leading to an unsustainable decision. The Court emphasized that the presumption of concealment is rebuttable, and the Revenue's appeal was allowed.