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    <title>2024 (12) TMI 1386 - ITAT DELHI</title>
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    <description>Statutory presumptions arising from seized loose papers under section 132(4A) and section 292C are rebuttable, and additions cannot rest solely on such papers once the assessee disowns them on a preponderance of probabilities. Here, no pointed questions were asked at search, no independent enquiry was made from the alleged contractor or other connected persons, and the Revenue produced no corroborative evidence. The assessee discharged the initial burden by denying ownership and attribution of the documents, while the Revenue failed to rebut that denial. The additions for unexplained expenditure and unexplained money were therefore not sustainable and were deleted.</description>
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    <pubDate>Wed, 18 Dec 2024 00:00:00 +0530</pubDate>
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      <title>2024 (12) TMI 1386 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=763806</link>
      <description>Statutory presumptions arising from seized loose papers under section 132(4A) and section 292C are rebuttable, and additions cannot rest solely on such papers once the assessee disowns them on a preponderance of probabilities. Here, no pointed questions were asked at search, no independent enquiry was made from the alleged contractor or other connected persons, and the Revenue produced no corroborative evidence. The assessee discharged the initial burden by denying ownership and attribution of the documents, while the Revenue failed to rebut that denial. The additions for unexplained expenditure and unexplained money were therefore not sustainable and were deleted.</description>
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      <pubDate>Wed, 18 Dec 2024 00:00:00 +0530</pubDate>
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