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    <title>2003 (1) TMI 229 - ITAT ALLAHABAD</title>
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    <description>Section 158BD requires the Assessing Officer to record objectively discernible satisfaction, from seized material, that undisclosed income belongs to a person other than the searched person; absent that satisfaction, proceedings are invalid. Block assessment is also confined to undisclosed income found through incriminating search material, so loans and gifts already disclosed in pre-search returns and balance-sheets, with corresponding bank entries on record, cannot be treated as undisclosed income merely because their genuineness is doubted. The assessment orders were quashed, and the additions based on disclosed loans and gifts were held unsustainable.</description>
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    <pubDate>Wed, 15 Jan 2003 00:00:00 +0530</pubDate>
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      <title>2003 (1) TMI 229 - ITAT ALLAHABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=56553</link>
      <description>Section 158BD requires the Assessing Officer to record objectively discernible satisfaction, from seized material, that undisclosed income belongs to a person other than the searched person; absent that satisfaction, proceedings are invalid. Block assessment is also confined to undisclosed income found through incriminating search material, so loans and gifts already disclosed in pre-search returns and balance-sheets, with corresponding bank entries on record, cannot be treated as undisclosed income merely because their genuineness is doubted. The assessment orders were quashed, and the additions based on disclosed loans and gifts were held unsustainable.</description>
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      <pubDate>Wed, 15 Jan 2003 00:00:00 +0530</pubDate>
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