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    <title>2018 (10) TMI 2072 - ITAT RAJKOT</title>
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    <description>Search-assessment additions require a nexus with incriminating material and cannot rest on unsupported estimates or uncorroborated declarations. Foreign derivative activity was taxable only to the extent of established trading profit, not on peak-credit basis; the initial-investment addition was deleted. Reversed, reconciled or temporary bullion-ledger entries, invoiced premium payments, hedging losses, interest expenditure, and unsupported property and cheque-purchase allegations did not justify additions. Credits lacking adequate substantiation, estimated deemed rent for a second residence, and commission disallowed for failure to deduct tax remained taxable or disallowable. The account was treated as beneficially owned by the assessee, but its derivative-trading character governed the taxable income computation.</description>
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      <link>https://www.taxtmi.com/caselaws?id=471094</link>
      <description>Search-assessment additions require a nexus with incriminating material and cannot rest on unsupported estimates or uncorroborated declarations. Foreign derivative activity was taxable only to the extent of established trading profit, not on peak-credit basis; the initial-investment addition was deleted. Reversed, reconciled or temporary bullion-ledger entries, invoiced premium payments, hedging losses, interest expenditure, and unsupported property and cheque-purchase allegations did not justify additions. Credits lacking adequate substantiation, estimated deemed rent for a second residence, and commission disallowed for failure to deduct tax remained taxable or disallowable. The account was treated as beneficially owned by the assessee, but its derivative-trading character governed the taxable income computation.</description>
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