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Third-party search material and uncorroborated seized papers...
Rebuttable search presumptions and corroboration standards shaped deletion of unsubstantiated additions, while rental income and limited profit estimates were sustained.
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Third-party search material and uncorroborated seized papers could not sustain on-money or unaccounted purchase additions where the documents lacked a clear nexus to the assessees and the presumptions under sections 132(4A) and 292C remained rebuttable; those additions were deleted. An unsigned, unregistered agreement to sell and contradictory valuation reports were likewise insufficient to support protective and substantive property additions. By contrast, undisclosed rental income admitted in search was sustained in the absence of any evidence that it belonged to an HUF. Stock shortages supported a limited gross profit addition, and for unaccounted sales in the liquor business the profit element was restricted to 3%, with separate additions for alleged purchases deleted.
Third-party search material and uncorroborated seized papers could not sustain on-money or unaccounted purchase additions where the documents lacked a clear nexus to the assessees and the presumptions under sections 132(4A) and 292C remained rebuttable; those additions were deleted. An unsigned, unregistered agreement to sell and contradictory valuation reports were likewise insufficient to support protective and substantive property additions. By contrast, undisclosed rental income admitted in search was sustained in the absence of any evidence that it belonged to an HUF. Stock shortages supported a limited gross profit addition, and for unaccounted sales in the liquor business the profit element was restricted to 3%, with separate additions for alleged purchases deleted.
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