The Bombay Dyeing Tax Case: A Landmark in Taxation Law?

The Bombay Dyeing & Mfg. Co. Ltd. vs. CIT (1983) 141 ITR 157 is a landmark case in Taxation Law, specifically dealing with the issue of transfer pricing. In this case, the Supreme Court of India held that if the arms-length price is not available, it is the duty of the assessee to prove the price that is adopted for the transaction. The court also stated that the burden of proof lies with the assesse (the assessee), which means they must prove that the price adopted is the arm's length price.

What do you all think about this judgment? Should the burden of proof always lie with the assessee? Can the government do more to prove the arm's length price? Share your thoughts!