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    <title>2003 (4) TMI 84 - PUNJAB AND HARYANA High Court</title>
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    <description>In block assessment proceedings, additions towards alleged undisclosed income cannot be sustained on mere estimate, conjecture, or presumption; the Revenue must show evidence with a direct nexus to the income alleged. The Tribunal treated the partnership firm as coming into existence only on 1 April 1986, so no business income could be attributed for the earlier assessment period. It also found the undisclosed investment addition unsupported because the material was not properly confronted to the assessee and no effective opportunity of hearing was given. The estimated interest income was similarly rejected because it rested on assumptions rather than proof.</description>
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    <pubDate>Fri, 04 Apr 2003 00:00:00 +0530</pubDate>
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      <title>2003 (4) TMI 84 - PUNJAB AND HARYANA High Court</title>
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      <description>In block assessment proceedings, additions towards alleged undisclosed income cannot be sustained on mere estimate, conjecture, or presumption; the Revenue must show evidence with a direct nexus to the income alleged. The Tribunal treated the partnership firm as coming into existence only on 1 April 1986, so no business income could be attributed for the earlier assessment period. It also found the undisclosed investment addition unsupported because the material was not properly confronted to the assessee and no effective opportunity of hearing was given. The estimated interest income was similarly rejected because it rested on assumptions rather than proof.</description>
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