Assessee was engaged in business of financing and leasing. Assessing Officer issued a reassessment notice based on fund movements in assessee’s bank account, treating them as taxable income.  Tribunal decided  in favor of assessee, holding that there was no taxable income involved relying on Supreme Court’s decision in Raja Naykar v. State of Chhattisgarh in [Criminal Appeal No. 902 of 2023, dated 24-1-2024] (a criminal case) and applied principle of “proof beyond reasonable doubt” to tax law concept of “reason to believe”. On appeal the Court held that  principles enunciated in criminal jurisprudence in respect of a proof beyond reasonable doubt was erroneously applied to an issue which was subject of provisions of Act and construction of words “reason to believe” as construed by Tribunal on anvil of said Supreme Court case, was absolutely erroneous. Accordingly the  Tribunal misdirected itself in predicating its entire reasoning on an incorrect and inapplicable principle of law, which are confined to purely penal provisions which was not present situation and, thus, on this error alone impugned judgement was found to be unsustainable in law and matter was to be remanded back to Tribunal to decide on merits.(AY. 2012-13,  2013-14)