Condition precedent for raising presumption under section 132(4A) read with section 292C of IT Act against a person searched

RELEVANT PARAGRAPHS : 29. We have considered the rival submissions and perused the material on record. In our considered view, the Revenue is basically relying on the presumption as contained in Section 132(4A) read with Section 292C. For the sake of convenience, we reproduce Sections 132(4A) and 292C as under: 132 (4A) Where any books of account, other documents, money, bullion, jewellery or other valuable article or thing are or is found in the possession or control of any person in the course of a search, it may be presumed – (i) that such books of account, other documents, money, bul...