Jantri valuation, completion certificates and survey disclosures determine housing-project deduction where factual findings lack contrary evidence.

Jantri valuation alone does not establish unexplained expenditure where no survey material or other evidence shows spending outside the books. Housing-project deduction may be supported by part-completion and final completion certificates where no contrary material demonstrates non-compliance with statutory conditions. Income disclosed during survey may qualify as business income for that deduction when the taxpayer carries on only construction business and no evidence identifies another source. The notes also state that no substantial question of law arises where concurrent factual findings are supported by the record and remain unrebutted.

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Issues: (i) Whether addition for unexplained expenditure could be sustained merely on jantri valuation without evidence of expenditure outside the books; (ii) whether deduction for the housing project was allowable on the basis of completion certificates; (iii) whether income disclosed during survey constituted business income eligible for the housing-project deduction.

Issue (i): Whether addition for unexplained expenditure could be sustained merely on jantri valuation without evidence of expenditure outside the books.

Analysis: The factual findings established that no material, including material found in survey, showed that any expenditure had been incurred outside the books. Jantri valuation alone did not establish undisclosed expenditure.

Conclusion: The deletion of the addition for unexplained expenditure was upheld in favour of the assessee.

Issue (ii): Whether deduction for the housing project was allowable on the basis of completion certificates.

Analysis: The competent authority had issued part-completion certificates and a final completion certificate for the entire project. No contrary material was produced to establish non-compliance with the statutory conditions for the deduction.

Conclusion: The allowance of deduction for the housing project was upheld in favour of the assessee.

Issue (iii): Whether income disclosed during survey constituted business income eligible for the housing-project deduction.

Analysis: The assessee carried on no business other than construction, and no evidence showed that the disclosed income arose from a source other than that business.

Conclusion: The disclosed income was held to be business income eligible for the deduction, in favour of the assessee.

Final Conclusion: The concurrent factual findings were not shown to be unsupported by evidence, and no substantial question of law arose.

Ratio Decidendi: A tax appeal does not give rise to a substantial question of law where concurrent factual findings are supported by the record and no contrary evidence is shown.

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