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Section 153C jurisdiction requires timely deemed search and assessee-specific satisfaction material; otherwise reassessment must use the proper statut...
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The assessee's investment in film financing business was examined based on seized documents and statements recorded during the search operation. The explanation that the assessee acted as a middleman/agent arranging finance for film producers through lenders was accepted as bonafide, considering the nature of the unorganized film financing sector. A 5% net profit margin on the total loans facilitated was determined as reasonable income, after allowing 1% deduction for expenditure. The addition for a gift received from the brother-in-law was upheld for one year due to lack of evidence establishing the relationship and creditworthiness of the donor. However, for another year, the gift was accepted based on confirmation, bank statements, and the identity of the donor being established, despite the lack of relationship proof. The unexplained cash found during the search was partially accepted, with the remaining unexplained portion added to income. The jewellery investment was directed to be deleted as an addition, considering the quantity fell within prescribed limits and the assessee explained the known sources.
The assessee's investment in film financing business was examined based on seized documents and statements recorded during the search operation. The explanation that the assessee acted as a middleman/agent arranging finance for film producers through lenders was accepted as bonafide, considering the nature of the unorganized film financing sector. A 5% net profit margin on the total loans facilitated was determined as reasonable income, after allowing 1% deduction for expenditure. The addition for a gift received from the brother-in-law was upheld for one year due to lack of evidence establishing the relationship and creditworthiness of the donor. However, for another year, the gift was accepted based on confirmation, bank statements, and the identity of the donor being established, despite the lack of relationship proof. The unexplained cash found during the search was partially accepted, with the remaining unexplained portion added to income. The jewellery investment was directed to be deleted as an addition, considering the quantity fell within prescribed limits and the assessee explained the known sources.
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