Officer the document has been
requisitioned under section 132A of the Act and, thus, provisions of
section 292C(2) would apply in the case ... assessee failed to rebut the presumption under
section 132(4) or presumption under section 292C of the Act.
5.10 Further, we find that the conclusion
belong to assessee whereas the A.O. invoking
provisions of section 292C made the additions.
4. Briefly stated, there was a search and seizure action ... accepted by
the A.O. and invoking provisions of section 292C , which places onus on the
assessee, made additions on the basis of entries
gentleman. The Ld. AR further argued that the provisions of
Section 132(4A) and 292C are the rebuttable presumptions. However,
no opportunity was given ... rebut the same. The Ld.
AR further stated that both these Sections do not give any right to the
Assessing Officer to presume contents
though there is a clear presumption
under law under Section 134-A read with Section 292C of the Income
Tax Act.
18.It is further ... indulge in corrupt electoral practice.
44.The presumption under Section 132(4A)(i) and Section 292C of
the IT Act, 1961 that the books
that cash and gold was found from appellant and
relying on Section 292C that the same belongs to appellant.
5. Without prejudice to above ... source of cash and relied on the provisions
of section 69A as well as section 292C. One of the reasons for the
rejection of assessee
premises of the assessee. Hence,
under the provision of section 292C of the Act, he would be considered as the
ITA no.2291/AHD/2017 ... other hand, the learned DR submitted that it is presumed under
section 292C of the Act that the documents found during the search from
Himland Agro Foods Ltd., Chandigarh vs Dcit, Chandigarh on 17 January, 2017
I N T
such person.
15.It has been further concluded that as per Section 292C(1)
of the Income Tax Act, 1961 also there is a presumption ... respondent is quashed.
43. Further, both under Section 132(4A) and Section 292C(1) ,
there is only a presumption. However, such presumptions are
rebuttable
assessee has given a loan to the parties. The provisions of section
292C and section 132(4A) of the Act clearly says that the
presumption ... examined under the provisions of Section 132(4A) and section 292C
of the Act. In view of this we do not agree with the order
presumption available to the Revenue against the assessee
in terms of Section 292C of the Act which enables the Revenue to
presume that the documents ... hands of the appellant
company by taking recourse to section 292C of the IT Act, 1961 is
not in accordance with law. Moreover, relying
