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    <title>2025 (6) TMI 1377 - ITAT RAJKOT</title>
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    <description>ITAT Rajkot allowed the appeal and deleted the addition made u/s 69A on protective basis. The tribunal held that when the Department failed to make substantive addition against the true owner of gold (supplier), it cannot collect taxes from the person where protective addition was made merely to safeguard revenue. Since the appellant was engaged in job-work and the supplier owned the gold, and no substantive addition was framed against the true owner, the assessee was not liable for the transactions as they were not the actual owner of the gold.</description>
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    <pubDate>Fri, 25 Apr 2025 00:00:00 +0530</pubDate>
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      <title>2025 (6) TMI 1377 - ITAT RAJKOT</title>
      <link>https://www.taxtmi.com/caselaws?id=773264</link>
      <description>ITAT Rajkot allowed the appeal and deleted the addition made u/s 69A on protective basis. The tribunal held that when the Department failed to make substantive addition against the true owner of gold (supplier), it cannot collect taxes from the person where protective addition was made merely to safeguard revenue. Since the appellant was engaged in job-work and the supplier owned the gold, and no substantive addition was framed against the true owner, the assessee was not liable for the transactions as they were not the actual owner of the gold.</description>
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      <pubDate>Fri, 25 Apr 2025 00:00:00 +0530</pubDate>
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