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    <title>2026 (5) TMI 1333 - ITAT DELHI</title>
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    <description>Section 69A could not be invoked where the Revenue failed to prove that the assessee was the owner of the cash in her own right. The seized digital records and statements showed only that cash generated through over-invoicing belonged to the company and that the assessee acted as a key person handling it; they did not establish personal ownership, personal benefit, or unaccounted assets in her possession. The absence of cogent evidence linking the unaccounted cash to her personal enrichment meant the statutory ownership requirement was not satisfied, so the addition was deleted and that deletion was upheld.</description>
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    <pubDate>Fri, 15 May 2026 00:00:00 +0530</pubDate>
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      <title>2026 (5) TMI 1333 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=792131</link>
      <description>Section 69A could not be invoked where the Revenue failed to prove that the assessee was the owner of the cash in her own right. The seized digital records and statements showed only that cash generated through over-invoicing belonged to the company and that the assessee acted as a key person handling it; they did not establish personal ownership, personal benefit, or unaccounted assets in her possession. The absence of cogent evidence linking the unaccounted cash to her personal enrichment meant the statutory ownership requirement was not satisfied, so the addition was deleted and that deletion was upheld.</description>
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      <pubDate>Fri, 15 May 2026 00:00:00 +0530</pubDate>
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