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2014 (11) TMI 47 - HC - Income TaxUndisclosed investment for the purchase of land and construction of house – Held that:- The DVO's estimation of cost of construction without furniture and fixture and that of the assessee's valuer, there is a minor difference of ₹ 1.22 lakhs - even if the AO had accepted the DVO's report in its entirety, the total addition under the head could not have exceeded ₹ 1.22 lakhs - the AO divided the undisclosed investment in the cost of construction in the three years - Even if this be so, we fail to see how the total of these three years of expenditure could exceed ₹ 1.22 lakhs which was the difference between the DVO's valuation and that of the valuation of the assessee's valuer, on the basis of which he filed the return - the assessee had made no disclosure towards the purchase of land in his statement during the search proceedings - The addition was made merely on the basis of the DVO's report without there being any other material - the DVO had also substantially relied on jantri rates and had made other references for arriving at the valuation – as such no question of law arises for consideration – Decided against revenue.
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