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    <title>1992 (3) TMI 104 - ITAT AHMEDABAD-C</title>
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    <description>Reassessment under section 147(a) was treated as valid because the assessee had waived the objection before the first appellate authority, and the seized diary contained specific material showing understatement of the property consideration and failure to disclose fully and truly all material facts. The fact that the department had possession of the diary before completion of the original assessment did not mean the incriminating contents were before the assessing authority. The addition for alleged on-money payment was sustained because the diary entries, read with the agreement and wealth-tax records, supported the inference of higher consideration, while the assessee&#039;s explanation was not credibly rebutted. The corresponding protective addition in the husband&#039;s hands was cancelled once the substantive addition survived in the wife&#039;s case.</description>
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    <pubDate>Mon, 09 Mar 1992 00:00:00 +0530</pubDate>
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      <title>1992 (3) TMI 104 - ITAT AHMEDABAD-C</title>
      <link>https://www.taxtmi.com/caselaws?id=56138</link>
      <description>Reassessment under section 147(a) was treated as valid because the assessee had waived the objection before the first appellate authority, and the seized diary contained specific material showing understatement of the property consideration and failure to disclose fully and truly all material facts. The fact that the department had possession of the diary before completion of the original assessment did not mean the incriminating contents were before the assessing authority. The addition for alleged on-money payment was sustained because the diary entries, read with the agreement and wealth-tax records, supported the inference of higher consideration, while the assessee&#039;s explanation was not credibly rebutted. The corresponding protective addition in the husband&#039;s hands was cancelled once the substantive addition survived in the wife&#039;s case.</description>
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      <pubDate>Mon, 09 Mar 1992 00:00:00 +0530</pubDate>
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