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    <title>2001 (3) TMI 294 - ITAT PUNE</title>
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    <description>An ad hoc search declaration under section 132(4) and an unaccepted settlement offer could not, by themselves, justify additions where the firms had already been dissolved and no incriminating material showed post-dissolution income. A search statement has evidentiary value only when supported by corroborative material, and a rejected settlement proposal cannot be treated as proof of taxable income. Additions based on alleged excess liabilities also failed because the Assessing Officer relied on presumptions of concealed assets and unaccounted payments without evidence, and the related year-end payment finding was inconsistent with the record.</description>
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    <pubDate>Wed, 28 Mar 2001 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=71847</link>
      <description>An ad hoc search declaration under section 132(4) and an unaccepted settlement offer could not, by themselves, justify additions where the firms had already been dissolved and no incriminating material showed post-dissolution income. A search statement has evidentiary value only when supported by corroborative material, and a rejected settlement proposal cannot be treated as proof of taxable income. Additions based on alleged excess liabilities also failed because the Assessing Officer relied on presumptions of concealed assets and unaccounted payments without evidence, and the related year-end payment finding was inconsistent with the record.</description>
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      <pubDate>Wed, 28 Mar 2001 00:00:00 +0530</pubDate>
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