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    <title>2025 (12) TMI 1033 - ITAT RAJKOT</title>
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    <description>Protective addition of the value of seized fine gold was in issue, where the assessee claimed to be only a job worker and not the owner. The ITAT held that a protective addition in the assessee&#039;s hands is unsustainable once the actual owners of the seized gold are identified and have accepted ownership, and substantive assessment has been made in the real owners&#039; cases with acceptance of tax liability. As the assessee failed to be shown as the beneficial owner and the substantive addition lay elsewhere, the protective addition was deleted and the appeal was allowed.</description>
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    <pubDate>Thu, 11 Dec 2025 00:00:00 +0530</pubDate>
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      <title>2025 (12) TMI 1033 - ITAT RAJKOT</title>
      <link>https://www.taxtmi.com/caselaws?id=783493</link>
      <description>Protective addition of the value of seized fine gold was in issue, where the assessee claimed to be only a job worker and not the owner. The ITAT held that a protective addition in the assessee&#039;s hands is unsustainable once the actual owners of the seized gold are identified and have accepted ownership, and substantive assessment has been made in the real owners&#039; cases with acceptance of tax liability. As the assessee failed to be shown as the beneficial owner and the substantive addition lay elsewhere, the protective addition was deleted and the appeal was allowed.</description>
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      <pubDate>Thu, 11 Dec 2025 00:00:00 +0530</pubDate>
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