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    <title>2025 (8) TMI 1873 - ITAT RAJKOT</title>
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    <description>The presumption for impounded documents attaches to the person from whose possession or control they were found; additions against a firm or other persons require independent corroborative evidence. Diary entries predating the firm, absence of commercial production, prior assessment in the individual&#039;s hands, and implausible agreement terms did not support additions for unexplained cash, land investment, or purchases. Where entries identify separate contributors, only the identified individual&#039;s cash contribution may be assessed, subject to telescoping against the finally determined share of unaccounted income. Separate land-payment and purchase additions were deleted as duplicative or unsupported. Residual unexplained jewellery and cash additions remained sustainable because their sources were not established.</description>
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      <title>2025 (8) TMI 1873 - ITAT RAJKOT</title>
      <link>https://www.taxtmi.com/caselaws?id=472001</link>
      <description>The presumption for impounded documents attaches to the person from whose possession or control they were found; additions against a firm or other persons require independent corroborative evidence. Diary entries predating the firm, absence of commercial production, prior assessment in the individual&#039;s hands, and implausible agreement terms did not support additions for unexplained cash, land investment, or purchases. Where entries identify separate contributors, only the identified individual&#039;s cash contribution may be assessed, subject to telescoping against the finally determined share of unaccounted income. Separate land-payment and purchase additions were deleted as duplicative or unsupported. Residual unexplained jewellery and cash additions remained sustainable because their sources were not established.</description>
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