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    <title>2025 (2) TMI 1526 - ITAT DELHI</title>
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    <description>Whether the addition under section 132(4A) read with section 69A could be sustained against a company director was resolved by applying the principle that the statutory presumption is rebuttable and the Revenue bears the burden to prove ownership contrary to records. The factual record showed lockers, rents, agreements and accounting in the company&#039;s name and no evidence linking seized cash and jewellery to the director personally; accordingly the presumption was applied against the company and the addition was not sustainable against the director.</description>
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      <description>Whether the addition under section 132(4A) read with section 69A could be sustained against a company director was resolved by applying the principle that the statutory presumption is rebuttable and the Revenue bears the burden to prove ownership contrary to records. The factual record showed lockers, rents, agreements and accounting in the company&#039;s name and no evidence linking seized cash and jewellery to the director personally; accordingly the presumption was applied against the company and the addition was not sustainable against the director.</description>
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