https://www.taxtmi.com/caselaws?id=201426 Dispute concerns additions based on a Valuation Officer (DVO) report where properties had been declared under the Voluntary Disclosure of Income Scheme (VDIS). The reasoning emphasises that absent incriminating material from search or other evidence showing payment beyond declared amounts, the primary burden of proof lies on the Revenue to establish understatement or concealment, and only upon discharge of that burden may the DVO valuation be relied upon. The DVO opinion alone is not actionable information without corroboration. Because the assessments and appellate decision predated the statutory cut-off, the Assessing Officer could not validly direct DVO valuation, and the appeal was dismissed in limine. en-us Tue, 17 Aug 2010 00:00:00 +0530 Fri, 30 Jan 2026 12:49:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=201426 Dispute concerns additions based on a Valuation Officer (DVO) report where properties had been declared under the Voluntary Disclosure of Income Scheme (VDIS). The reasoning emphasises that absent incriminating material from search or other evidence showing payment beyond declared amounts, the primary burden of proof lies on the Revenue to establish understatement or concealment, and only upon discharge of that burden may the DVO valuation be relied upon. The DVO opinion alone is not actionable information without corroboration. Because the assessments and appellate decision predated the statutory cut-off, the Assessing Officer could not validly direct DVO valuation, and the appeal was dismissed in limine. Case-Laws Income Tax Tue, 17 Aug 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=201426