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ITAT addressed unexplained investments during a search u/s 132. Nine wrist watches seized were deemed inadmissible under section 69, as they should have been evaluated under section 69A. Jewellery valued at Rs. 96,15,563/- was treated as explained, with the CIT(A)'s deletion of Rs. 1,07,22,844/- upheld. Regarding ownership of 6200 grams of jewellery, the tribunal directed the Assessing Officer to re-examine claimants' statements and verify ownership substantively. The presumption of ownership under section 132(4) remained rebuttable. The Revenue's appeal was partially allowed for statistical purposes, with specific directions for further investigation into the jewellery's provenance.
ITAT addressed unexplained investments during a search u/s 132. Nine wrist watches seized were deemed inadmissible under section 69, as they should have been evaluated under section 69A. Jewellery valued at Rs. 96,15,563/- was treated as explained, with the CIT(A)'s deletion of Rs. 1,07,22,844/- upheld. Regarding ownership of 6200 grams of jewellery, the tribunal directed the Assessing Officer to re-examine claimants' statements and verify ownership substantively. The presumption of ownership under section 132(4) remained rebuttable. The Revenue's appeal was partially allowed for statistical purposes, with specific directions for further investigation into the jewellery's provenance.
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