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    <title>1999 (3) TMI 679 - ITAT MUMBAI</title>
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    <description>Approval under section 158BG was treated as an administrative safeguard, not a fresh assessment, so no prior hearing was required absent an express statutory mandate. The natural justice objection therefore failed. On additions, gold found in the assessee&#039;s possession was sustained because possession raised a rebuttable presumption of ownership and the assessee did not discharge the burden of explaining source or title. Additions based only on inconsistent statements about earlier consignments and house renovation, without independent corroboration, were deleted. A misdescription of the statutory provision was held not fatal where the facts supported taxation of unexplained acquisition.</description>
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    <pubDate>Tue, 09 Mar 1999 00:00:00 +0530</pubDate>
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      <title>1999 (3) TMI 679 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=176808</link>
      <description>Approval under section 158BG was treated as an administrative safeguard, not a fresh assessment, so no prior hearing was required absent an express statutory mandate. The natural justice objection therefore failed. On additions, gold found in the assessee&#039;s possession was sustained because possession raised a rebuttable presumption of ownership and the assessee did not discharge the burden of explaining source or title. Additions based only on inconsistent statements about earlier consignments and house renovation, without independent corroboration, were deleted. A misdescription of the statutory provision was held not fatal where the facts supported taxation of unexplained acquisition.</description>
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      <pubDate>Tue, 09 Mar 1999 00:00:00 +0530</pubDate>
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