Concealment presumption in tax searches treats found assets as concealed unless earlier books or commissioner disclosure exist.

Amendment provides that where assets are found in a search and the assessee claims they were acquired from income, the assessee is deemed to have concealed income or furnished inaccurate particulars for penalty purposes unless the income or transactions are recorded in books of account before the search date (for prior years) or on or before that date (for years ending on or after the search), or the income is otherwise disclosed to the Commissioner before that date.

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