Evidence submitted during assessment cannot be rejected merely for non submission at the time of seizure

CIT Vs Rakesh Ramani (Bombay High Court) In the present case, the entire grievance of the appellant that the impugned order is perverse stands nullified by the fact that the first ground of appeal taken by the appellant is that “it is doubtful whether the jewellery belongs to assessee or assessee’s employer”. Thus, even the Revenue is not certain about the ownership of the seized jewellery. Besides, the entire basis of the Revenue’s case is the statement made on the date of the seizure. The voluminous evidence filed by the respondent during the course of the assessment proceedi...