1987 (1) TMI 1 - SUPREME COURT

If the returned income is less than assessed income, the presumption is raised against the assessee that the assessee is guilty of fraud as a result of which he has concealed the income but this presumption can be rebutted. The rebuttal must be on materials relevant - It is for the fact-finding body to judge the relevancy of the materials - If such a fact-finding body, comes to the conclusion that the assessee has discharged the onus; it becomes a conclusion of fact. No question of law arises.