The reassessment was based on information received from the Investigation Wing alleging that the assessee had obtained accommodation entries for purchase of diamonds. The assessee consistently denied having purchased goods from the alleged supplier and produced its purchase registers and tax audit report showing no such purchases. The Tribunal held that the Revenue had failed to establish the existence of the alleged purchases by any cogent evidence. Since the burden of proving the conditions for taxability lay on the Revenue, the assessee could not be required to prove a negative. The addition under section 69C was deleted. (AY. 2012-13).