Burden of Proof is not Static

“the taxpayer’s initial onus of “demolishing” the Minister’s exact assumptions is met where the appellant makes out at least prima facie case; where the Minister’s assumptions have been “demolished” by the appellant, “the onus … shifts to the Minister to rebut the prima facie case” made out by the
appellant and to prove the assumptions; … the law is settled that unchallenged and uncontradicted evidence “demolishes” the Minister’s assumptions;…. JUDGMENT- APPEAL NO. 449 OF 2022 – VIRAJ DEVELOPMENT LIMITED–VS- COMMISSIONER OF INVESTIGATIONS AND ENFORCEMENT PG 46 OF
48 where the burden has shifted to the Minister, and the Minister adduces no evidence
whatsoever, the taxpayer is entitled to succeed; and even if the evidence contained “gaps in logic, chronology, and substance”, the taxpayer’s appeal will be allowed if Minister fails to present any evidence as to the source of income.”