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    <title>2019 (9) TMI 378 - ITAT MUMBAI</title>
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    <description>In completed assessments under section 153A, additions cannot survive unless supported by incriminating material found during search; information available earlier, without search-seized evidence, is insufficient. The commentary also states that an addition under section 69A requires proof that the assessee owned or beneficially owned the money or asset in question. Where HSBC bank balances stood in the names of third-party entities, the assessee denied ownership and the record did not establish control or ownership in his hands, so the unexplained money addition was not sustainable. The appellate order deleting both additions was upheld and the Revenue&#039;s challenge failed.</description>
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    <pubDate>Fri, 06 Sep 2019 00:00:00 +0530</pubDate>
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      <title>2019 (9) TMI 378 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=385610</link>
      <description>In completed assessments under section 153A, additions cannot survive unless supported by incriminating material found during search; information available earlier, without search-seized evidence, is insufficient. The commentary also states that an addition under section 69A requires proof that the assessee owned or beneficially owned the money or asset in question. Where HSBC bank balances stood in the names of third-party entities, the assessee denied ownership and the record did not establish control or ownership in his hands, so the unexplained money addition was not sustainable. The appellate order deleting both additions was upheld and the Revenue&#039;s challenge failed.</description>
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      <pubDate>Fri, 06 Sep 2019 00:00:00 +0530</pubDate>
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