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    <title>2010 (8) TMI 65 - DELHI HIGH COURT</title>
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    <description>Addition under unexplained cash valuation was challenged where the valuation report relied upon was obtained after search proceedings. The court emphasised that the primary burden of proof to establish concealment or understatement rests with the revenue, and absent incriminating material discovered during the search there is no basis to invoke a later valuation report by the DVO. Consequently, additions based solely on post-search valuation were deleted by the appellate authorities, and the departmental appeal was dismissed in limine.</description>
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      <title>2010 (8) TMI 65 - DELHI HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=78246</link>
      <description>Addition under unexplained cash valuation was challenged where the valuation report relied upon was obtained after search proceedings. The court emphasised that the primary burden of proof to establish concealment or understatement rests with the revenue, and absent incriminating material discovered during the search there is no basis to invoke a later valuation report by the DVO. Consequently, additions based solely on post-search valuation were deleted by the appellate authorities, and the departmental appeal was dismissed in limine.</description>
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