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    <title>2024 (12) TMI 895 - ITAT AMRITSAR</title>
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    <description>ITAT Amritsar set aside additions made under Section 153A based solely on statements recorded during search operations. The tribunal held that sworn statements obtained during search/survey cannot automatically bind the assessee without corroborating tangible evidence. Following SC precedent in CIT Salem case and CBDT circular, the tribunal ruled that materials collected under Section 133A are not conclusive evidence by themselves. Additions under Section 69C for unexplained marriage expenditure and foreign tour expenses were deleted due to lack of supporting documents. Addition under Section 69B based solely on DVO valuation report was also set aside, as courts have established that valuation reports are merely guidance tools and cannot sustain additions without additional evidence establishing unaccounted investment.</description>
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    <pubDate>Fri, 18 Oct 2024 00:00:00 +0530</pubDate>
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      <title>2024 (12) TMI 895 - ITAT AMRITSAR</title>
      <link>https://www.taxtmi.com/caselaws?id=763315</link>
      <description>ITAT Amritsar set aside additions made under Section 153A based solely on statements recorded during search operations. The tribunal held that sworn statements obtained during search/survey cannot automatically bind the assessee without corroborating tangible evidence. Following SC precedent in CIT Salem case and CBDT circular, the tribunal ruled that materials collected under Section 133A are not conclusive evidence by themselves. Additions under Section 69C for unexplained marriage expenditure and foreign tour expenses were deleted due to lack of supporting documents. Addition under Section 69B based solely on DVO valuation report was also set aside, as courts have established that valuation reports are merely guidance tools and cannot sustain additions without additional evidence establishing unaccounted investment.</description>
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      <pubDate>Fri, 18 Oct 2024 00:00:00 +0530</pubDate>
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