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    <title>2025 (3) TMI 1975 - ITAT MUMBAI</title>
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    <description>Section 69A of the Income-tax Act, 1961 applies to unexplained jewellery found during the relevant assessment year. Jewellery seized on 10 April 2018 was found in the financial year relevant to Assessment Year 2019-20, not Assessment Year 2018-19; accordingly, the analysis treats an addition for the earlier year as unsustainable. Income from brokerage and commission had already been disclosed in the returns under Sections 139(1) and 153A, with taxes and interest paid, and was stated to have funded the jewellery acquisition. Re-characterising that disclosed income under Section 69A and applying Section 115BBE for Assessment Year 2018-19 was therefore considered impermissible, and the stated conclusion was deletion of the addition and consequential taxation.</description>
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      <title>2025 (3) TMI 1975 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=470067</link>
      <description>Section 69A of the Income-tax Act, 1961 applies to unexplained jewellery found during the relevant assessment year. Jewellery seized on 10 April 2018 was found in the financial year relevant to Assessment Year 2019-20, not Assessment Year 2018-19; accordingly, the analysis treats an addition for the earlier year as unsustainable. Income from brokerage and commission had already been disclosed in the returns under Sections 139(1) and 153A, with taxes and interest paid, and was stated to have funded the jewellery acquisition. Re-characterising that disclosed income under Section 69A and applying Section 115BBE for Assessment Year 2018-19 was therefore considered impermissible, and the stated conclusion was deletion of the addition and consequential taxation.</description>
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