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TMI Blog2002 (10) TMI 340X X X X Extracts X X X X X X X X Extracts X X X X ..... r the assessment year 1986-87 are directed against the Order of the CIT(A). Since identical issues are involved in both the appeals these are being decided with this common Order. 2. The only issue in this appeal is regarding the validity of re-opening of assessment. The Ld. DR argued that the assessee has grossly understated the value of jewellery and silver articles in the original return of w ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he Ld. counsel for the assessee has opposed these arguments. He argued that the assessee has declared the value of jewellery year after year right from the beginning as per the balance sheet representing the cost of acquisition of the jewellery. The assessee later on realised that the value of jewellery should have been declared on the basis of its market value as on the relevant valuation dates a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ional wealth-tax thereof. The same jewellery has been declared year after year by the assessee and there is no difference in the quantity thereof and the difference is due to the appreciation in the value of the precious metal. The case law cited by the Ld. DR does not help the case of the revenue since the reasons recorded for re-opening the assessment are non-existent. The assessee derived incom ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... quantity of jewellery than what was declared already by the assessee and other members were found at the time of search. There is no material before us to contradict the finding of the CIT(A) in holding that there is no material on record to disprove the assessee s claim that the same quantity of different items of jewellery continued to be owned by the assessee since assessment year 1979-80 and t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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