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    <title>1991 (1) TMI 199 - ITAT DELHI-A</title>
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    <description>A search-seizure paper cannot, by itself, justify an addition as unexplained investment in regular assessment unless the Department produces independent material linking the document to the assessee and satisfying section 69. The presumption under section 132(4A) was treated as confined to search proceedings and could not replace proof of ownership or investment in the relevant year, so the additions based on the seized paper were deleted. The estimated additions in trading results and job work receipts were also deleted because the declared figures were broadly consistent with earlier years and the Revenue brought no convincing contrary material.</description>
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    <pubDate>Wed, 30 Jan 1991 00:00:00 +0530</pubDate>
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      <title>1991 (1) TMI 199 - ITAT DELHI-A</title>
      <link>https://www.taxtmi.com/caselaws?id=63177</link>
      <description>A search-seizure paper cannot, by itself, justify an addition as unexplained investment in regular assessment unless the Department produces independent material linking the document to the assessee and satisfying section 69. The presumption under section 132(4A) was treated as confined to search proceedings and could not replace proof of ownership or investment in the relevant year, so the additions based on the seized paper were deleted. The estimated additions in trading results and job work receipts were also deleted because the declared figures were broadly consistent with earlier years and the Revenue brought no convincing contrary material.</description>
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      <pubDate>Wed, 30 Jan 1991 00:00:00 +0530</pubDate>
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