Burden To Prove That Best Assessment By Income Tax Authorities Is Perverse Is On Assesee: Allahabad High Court

The Allahabad High Court has reiterated that the "burden of proof to prove a 'best judgment assessment' as perverse lies with the assessee." This ruling clarifies the legal standard in cases where a tax authority makes an assessment based on its best judgment due to the taxpayer's non-cooperation or lack of proper records. The court stated that once such an assessment is made, the taxpayer must present compelling evidence to prove that the assessment was not only incorrect but was also made arbitrarily or without proper basis.