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    <title>1991 (2) TMI 192 - ITAT JAIPUR</title>
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    <description>In the absence of a search under the Income-tax Act, the statutory presumption of ownership could not be applied to sustain additions based only on customs material and the assessee&#039;s disputed statement. Because the customs proceedings had not attained finality and the Assessing Officer had not independently verified the alleged possession, retraction, or ownership, the additions relating to gold biscuits, US dollars and foreign-trip expenditure were remitted for fresh consideration. An unexplained capital deposit of Rs. 11,800 was deleted because the assessee&#039;s savings-account explanation had not been examined. The addition for low household withdrawals was upheld as deleted, since it lacked supporting material and further enquiry.</description>
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    <pubDate>Thu, 07 Feb 1991 00:00:00 +0530</pubDate>
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      <title>1991 (2) TMI 192 - ITAT JAIPUR</title>
      <link>https://www.taxtmi.com/caselaws?id=68012</link>
      <description>In the absence of a search under the Income-tax Act, the statutory presumption of ownership could not be applied to sustain additions based only on customs material and the assessee&#039;s disputed statement. Because the customs proceedings had not attained finality and the Assessing Officer had not independently verified the alleged possession, retraction, or ownership, the additions relating to gold biscuits, US dollars and foreign-trip expenditure were remitted for fresh consideration. An unexplained capital deposit of Rs. 11,800 was deleted because the assessee&#039;s savings-account explanation had not been examined. The addition for low household withdrawals was upheld as deleted, since it lacked supporting material and further enquiry.</description>
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      <pubDate>Thu, 07 Feb 1991 00:00:00 +0530</pubDate>
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