Presumption of ownership in search seizures supports retention of KVPs and NSCs until assessment is completed.

KVPs and NSCs found in a person's possession during search attract the statutory presumption that they belong to that person, unless displaced by material at the appropriate stage. The petitioner's claim that some instruments stood in other names and were pledged articles did not rebut the presumption on the facts stated, and the question of third-party ownership was left for assessment. Retention of the seized securities for that purpose was treated as consistent with the statutory scheme governing assessment, retention and release, so the seizure and continued refusal to release the instruments were upheld as lawful.

---

---

Issues: Whether the seizure and continued retention of KVPs and NSCs found in the petitioner's possession during search were lawful, and whether the presumption under section 132(4A)(i) justified treating those assets as belonging to the petitioner pending assessment.

Analysis: Assets found in the possession or control of a person during search attract the statutory presumption that they belong to that person. The KVPs and NSCs were recovered from the petitioner's possession and control, and the competing claim that some instruments stood in other names and were pledged articles did not displace the presumption at this stage. Whether the securities actually belonged to third parties was a matter requiring proper examination during assessment. The retention of seized material for that purpose was also consistent with the time available for completion of assessment and the statutory scheme governing retention and release.

Conclusion: The seizure and refusal to release the KVPs and NSCs were held lawful, and the challenge to retention of the seized securities failed.

---