The assessee cannot be asked to prove with witnesses and documentary evidences the non-occurring of an event

“The AO is not justified in concluding that the assessee failed to prove that no cash transaction has taken place and that no independent witness or documentary evidence was produced to prove that the cash transaction did not take place. It was upon the AO to prove that the cash transactions of Rs.2,00,00,000/- took place rather than upon the assessee to prove that it did not take place. It is not proper on the part of the AO to ask the assessee was asked to prove with witnesses and documentary evidences a non-occurring of an event. The witnesses and documentary are called upon to prove an occurrence of the event not the non-occurrence of it.”