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2024 (1) TMI 354 - ITAT DELHIAddition u/s 69A - Search and seizure and survey operation u/s 132/133A as conducted on the assessee and other family members as well as the entire group - jewelleries and three watches were sent for valuation to a registered Valuer - HELD THAT:- As assessee had enough means to invest in the wrist watches. It will be pertinent to mention that the departmental authorities have accepted the source of investment in jewelleries found at the time of search and seizure operation. Only because bills and invoices of the wrist watches were not found at the time of search, the addition has been made. Thus we are of the view that the provisions of section 69A will not be attracted as the explanation offered by the assessee regarding the source of investment in the wrist watches, by no means, can be considered to be unsatisfactory. On the contrary, the explanation offered by the assessee appears to be plausible. Thus, in our view, the addition made under section 69A of the Act is unsustainable. While coming to such conclusion, we have drawn support from the decision of the Coordinate Bench in case of ACIT Vs. Gurnam Arora [2016 (4) TMI 249 - ITAT DELHI]. Accordingly, we delete the addition. Grounds are allowed.
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