COMMISSIONER OF INCOME TAX, KARNATAKA vs M/S BEDI & COMPANY PRIVATE LIMITED

The Supreme Court upheld the Karnataka High Court's decision that the Income Tax Tribunal was justified in treating the sum of Rs. 32,58,500 as a loan rather than income from business for the assessment year 1960-61. The Court emphasized that the burden of proof lies with the Revenue to demonstrate that the apparent loan was not genuine, as per Section 147(a) and Section 144 of the Income Tax Act, 1961. The appeal by the Revenue was dismissed, affirming the High Court's ruling in favor of the assessee.