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of <h1>Challenges to Tax Assessments Overturned Due to Improper Investigation</h1> The appeals were filed challenging assessments for the years 1973-74 and 1974-75 due to improper investigation into property construction costs and ... - Issues:1. Proper investigation in determining the cost of construction of property.2. Reliability of books of account maintained by the assessee for property construction.3. Addition of income from undisclosed sources.4. Validity of additions made by the ITO.Detailed Analysis:1. The appeals were filed due to the CIT setting aside the assessments for the asst. yrs. 1973-74 and 1974-75 as assessments were made without proper investigation into the cost of construction of property. The CIT required the ITO to determine the reliability of the books of account maintained by the assessee for property construction before making assessments.2. The ITO made additions to the assessments for the asst. yrs. 1973-74 and 1974-75, alleging that the assessee used income from undisclosed sources in property construction. The assessee contended that detailed accounts were maintained, supported by bills and vouchers, and objected to the rejection of the books of account by the ITO. The Tribunal found no reason to set aside the assessments and directed the ITO to delete the additions made by the ITO.3. In the appeal for the asst. yr. 1973-74, the ITO added income from the firm of M/s. Gujarat Motor Repowering Service to the total income of the assessee. The Tribunal, based on a previous decision and citing relevant case law, directed the ITO to delete the addition from the total income of the assessee.4. The last ground of appeal for the asst. yr. 1973-74 involved additions of Rs. 950 and Rs. 9,000 as income from undisclosed sources. The ITO added these amounts to meet household expenses, which the Tribunal confirmed. Similarly, in the appeal for the asst. yr. 1974-75, the Tribunal directed the ITO to delete certain additions, while confirming others related to undisclosed income sources.5. The Tribunal partially allowed the appeals for both years, addressing various grounds of appeal and confirming or deleting additions made by the ITO based on the evidence and arguments presented during the proceedings.
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