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Whether on the facts and circumstances of thecaseand in law, the Tribunal was justified in deleting addition of Rs. 8,57,00,000/on account of unexplained income appearing in the name of Pan Asian Distribution Ltd by not appreciating the document containing the details was seized during the course ofsearchand therefore the presumptions envisaged in the provisions of Section 132(4A) as well as provision of Section 292C are squarely applicable in thecaseof the assessee and consequently the AO was justified in treating the said amount as the assessee's unexplained income?

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Sec. 69C, 132 & 292C of Income Tax Act, 1961—Search and Seizure— Mere letter from the bank would not establish a relation between the payable amount and the assessee, particularly when the draft was in favour of a limited Company and as the recorded documents were not seized from the possession of the Assessee but during the raid from a third party, no question of law, therefore arises - PR. CIT V/s HASSAN ALI KHAN - [2020] 426 ITR 556 (BOM)

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