During assessment proceedings the AO noted that the assessee, while declaring the income from capital gains, had claimed certain amount towards cost of improvement of the property sold. The assessee produced vouchers, which the Assessing Officer stated were self-made. He held that no evidence of improvement or tax deduction at source on the payment made was provided by the assessee. Accordingly, he disallowed the deduction claimed by the assessee of the cost of improvement while calculating the capital gains earned. The Commissioner (Appeals) confirmed the addition observing that merely making entries in the books of account with regard to expenses on improvements and producing bills that run contra to common sense business practices, did not discharge the initial burden of proof on the assessee. On appeal, the Tribunal held that the initial burden of proof rested on the assessee to substantiate his claim of having incurred expenditure on improvement of the property. But the assessee failed on this count. Except for filing copies of invoices of the contractor through whom the work was done, no other evidence was filed by the assessee. Also, the invoices were deficient in several respects. There was no mention of the nature of work done for which the invoices were raised, the address on the invoice was incomplete since letters issued by the Department on the address were returned by the Postal Department with the comment “incomplete address”. No evidence regarding payment made to the contractor was filed by the assessee. It was not clear whether the bills raised served as receipts also and even if they did, they did not bear any revenue stamp to evidence receipt of money by the contractor. The assessee failed on all counts and parameters to establish the genuineness of its claim. The claim of the assessee to improvement in property was rightly disallowed. (AY.  2011-12)