Jewellery cannot be treated as unexplained merely for continuance of sale jewellery for years

Shri Raj Kumar Kakrania Vs DCIT (ITAT Delhi)

The reason given by the ld. CIT (A) for not accepting the assessee’s contention is that, the wealth tax return was filed 19 years earlier and it is difficult to believe that the same jewellery continued till the date of search. Such reason alone cannot be held to be tenable without any contrary material found during the course of search, because if the overall quantity of jewellery has been said to be available with the assessee and his wife much prior to the date of search and the same has been disclosed then presumption is that the

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