Substantive Additions Require Evidence; Protective Additions Apply to Ownership Uncertainty

Manjulaben Bipinbhai Patel Legal Heir of Late Bipinbhai P. Patel Vs DCIT (ITAT Ahmedabad) In the case of Manjulaben Bipinbhai Patel, Legal Heir of Late Bipinbhai P. Patel Vs Deputy Commissioner of Income Tax (ITAT Ahmedabad), the primary issue revolved around the addition of Rs. 1,03,86,888 in respect of unexplained jewellery found during a search operation for Assessment Year 2016-17. The jewellery addition was originally made on a substantive basis (50%) in the hands of Jigishaben Patel and on a protective basis (50%) in the hands of Manjulaben Patel. However, during appellate proceedings, i...