DVO valuation cannot override registered sale price without evidence of unrecorded payment, and concurrent factual findings were upheld.

A DVO valuation alone cannot displace the registered sale consideration for a property where no material shows unrecorded payment; the addition for alleged undisclosed investment was therefore unsustainable. A notional fair-rent addition for the Bhagirath Place shop was also unjustified because the factual finding was that the shop remained vacant and no material proved receipt of rent beyond what was declared. The explanation for cash found during search was accepted on the basis of the company's books, and those concurrent findings were not shown to be perverse. On these factual findings, no substantial question of law arose and the Revenue's appeal failed.

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Issues: (i) Whether the addition towards alleged undisclosed investment in the Punjabi Bagh property was sustainable on the basis of the DVO valuation report; (ii) whether the addition towards fair rental value of the Bhagirath Place shop was justified; (iii) whether the addition towards unexplained cash found during search was valid.

Issue (i): Whether the addition towards alleged undisclosed investment in the Punjabi Bagh property was sustainable on the basis of the DVO valuation report.

Analysis: The valuation reference was not supported by any material found in search. There was no nexus between the separate property at Baddi and the Punjabi Bagh property. The declared consideration in the registered sale deed could not be displaced merely by the DVO estimate, and any difference in contribution between co-purchasers was only a matter of their internal arrangement.

Conclusion: The addition was unsustainable and was rightly deleted.

Issue (ii): Whether the addition towards fair rental value of the Bhagirath Place shop was justified.

Analysis: The factual finding was that the shop remained vacant throughout the assessment year. No material was brought to show receipt of rent beyond what was declared. The concurrent factual findings of the appellate authorities were not shown to be perverse.

Conclusion: The addition was rightly deleted.

Issue (iii): Whether the addition towards unexplained cash found during search was valid.

Analysis: The assessee explained the cash recovery with reference to the books of account of the concerned company, and the Revenue failed to establish that the factual findings accepting that explanation were perverse.

Conclusion: The addition was rightly deleted.

Final Conclusion: No substantial question of law arose from the concurrent factual findings, and the Revenue's appeal failed.

Ratio Decidendi: A DVO valuation cannot override the actual sale consideration in the absence of material indicating unrecorded payment, and concurrent findings of fact on rental income and cash explanation will not be disturbed unless shown to be perverse.

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