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Issues: Whether the addition made under section 69C to the extent of Rs. 31,703 and Rs. 40,000 could be sustained in block assessment on the basis of the facts and circumstances found during search.
Analysis: The addition of Rs. 31,703 was sustained because no expenditure was shown for grah pravesh, death of the assessee's father, and birth of granddaughters. The addition of Rs. 40,000 was sustained in relation to marriage expenses of two sons. The Tribunal relied on the material found during search, including the status of the family and the jewellery and cash discovered, and treated the additions as founded on appreciation of the relevant facts. On that basis, the Court held that the additions could not be said to have been made without material or without consideration of the record.
Conclusion: The addition under section 69C was held to be sustainable and the challenge to it failed.