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    <title>2011 (2) TMI 1525 - ITAT COCHIN</title>
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    <description>Section 69A treats bullion, jewellery or other valuable articles found in a person&#039;s possession as income unless the nature and source of acquisition are satisfactorily explained. Possession also raises a prima facie presumption of ownership, shifting the burden to the possessor to rebut it with contemporaneous and credible evidence. Here, the explanation based on employment with a jeweller, a stock register and an issue challan was found internally inconsistent, unsupported by regular business records, and unable to reconcile the contradictions regarding where, when and in what quantity the ornaments were issued or carried. The seized jewellery was therefore not satisfactorily explained, and the addition under section 69A was sustained.</description>
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    <pubDate>Wed, 09 Feb 2011 00:00:00 +0530</pubDate>
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      <title>2011 (2) TMI 1525 - ITAT COCHIN</title>
      <link>https://www.taxtmi.com/caselaws?id=194386</link>
      <description>Section 69A treats bullion, jewellery or other valuable articles found in a person&#039;s possession as income unless the nature and source of acquisition are satisfactorily explained. Possession also raises a prima facie presumption of ownership, shifting the burden to the possessor to rebut it with contemporaneous and credible evidence. Here, the explanation based on employment with a jeweller, a stock register and an issue challan was found internally inconsistent, unsupported by regular business records, and unable to reconcile the contradictions regarding where, when and in what quantity the ornaments were issued or carried. The seized jewellery was therefore not satisfactorily explained, and the addition under section 69A was sustained.</description>
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