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The Income Tax Appellate Tribunal held that cash found in two lockers belonged to RNB Temple Trust and Ram Bajaj Foundation. The Trust's balance sheet showed cash in hand of Rs. 1,79,00,000, explaining the addition of Rs. 4,00,000 sustained by the CIT(A). The Foundation's balance sheet was accepted in its assessment, and the locker was operated before the search. The cash in the lockers, earmarked for temple construction and running an educational institution, matched the declared cash in both entities' balance sheets. Considering the circumstances, the Tribunal presumed the cash belonged to the Trust and Foundation, not the Bajaj family members, and deleted the addition made by the CIT(A), deciding in favor of the assessee.
The Income Tax Appellate Tribunal held that cash found in two lockers belonged to RNB Temple Trust and Ram Bajaj Foundation. The Trust's balance sheet showed cash in hand of Rs. 1,79,00,000, explaining the addition of Rs. 4,00,000 sustained by the CIT(A). The Foundation's balance sheet was accepted in its assessment, and the locker was operated before the search. The cash in the lockers, earmarked for temple construction and running an educational institution, matched the declared cash in both entities' balance sheets. Considering the circumstances, the Tribunal presumed the cash belonged to the Trust and Foundation, not the Bajaj family members, and deleted the addition made by the CIT(A), deciding in favor of the assessee.
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