https://www.taxtmi.com/caselaws?id=466239 Additions in search assessments must rest on cogent, positive materials found during search; mere loose sheets or diary entries cannot sustain additions, and the legal presumption that cash found in premises belongs to the premises owner does not substitute for proof. Reliance on witness statements without affording cross-examination violates natural justice and discredits those statements, requiring deletion of additions based on them. On property dealings, the transaction was not established as an exchange and possession findings limited the assessees rights; therefore no income arose under the valuation and deemed receipt rules relied upon by the revenue. Consequent substantive and protective additions under capital gains and deemed income principles were deleted and grounds allowed for the assessee. en-us Fri, 21 Feb 2025 00:00:00 +0530 Fri, 30 Jan 2026 19:20:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466239 Additions in search assessments must rest on cogent, positive materials found during search; mere loose sheets or diary entries cannot sustain additions, and the legal presumption that cash found in premises belongs to the premises owner does not substitute for proof. Reliance on witness statements without affording cross-examination violates natural justice and discredits those statements, requiring deletion of additions based on them. On property dealings, the transaction was not established as an exchange and possession findings limited the assessees rights; therefore no income arose under the valuation and deemed receipt rules relied upon by the revenue. Consequent substantive and protective additions under capital gains and deemed income principles were deleted and grounds allowed for the assessee. Case-Laws Income Tax Fri, 21 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466239