In the matter of the inductive assessment of business income for IRPEG and VAT purposes, pursuant to Article 39 of Presidential Decree No. 600 of 1973 and Article 54 of Presidential Decree No. 633 of 1972, the existence of a negative cash balance (which is a quite strange situation), implying that the expenditure items are larger than the revenue recorded, in addition to constituting an accounting anomaly, gives rise to the presumption of the existence of unrecorded revenue to an extent at least equal to the deficit.

In addition, with regard to the assessment of income taxes, if the assessment carried out by the tax office is based on the verification of bank accounts, the burden of proof of the Administration is satisfied, …, through the data and elements resulting from the aforesaid accounts, while the burden of proof is reversed on the taxpayer, who must demonstrate that the elements deducible from the bank movements are not referable to taxable transactions, providing, to this end, non-generic proof.