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2014 (1) TMI 858 - AT - Income TaxDeletion made on account of investment – Acquisition of unquoted shares – Held that:- There is no evidence for backing up the rate of land and the cost of construction in the earlier valuation report - The cost of construction worked out by the valuer in the valuation report comes nearer to the cost of construction declared by M/s. Superior Builders Limited in its audited books of account - There is no material on record which could show that there has been any unaccounted investment in the construction of the building – there was no ground for rejecting the amount of expenditure debited in the regular course for the construction of the building - In the absence of any corroborative and incriminating documents, any third party material cannot be made basis for making the addition - The burden casted on the revenue cannot be said to be discharged merely on relying on the valuation report prepared for a different purpose obtained by issuing notice u/s 133(6) of the Income- tax Act - There must have been some material which could establish that there has been unaccounted transaction for acquiring the share – Decided against Revenue.
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