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    <title>2026 (4) TMI 1485 - ITAT DELHI</title>
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    <description>An addition for alleged under-valuation of export sales was found unsustainable where the valuation report was prepared only from documents on record, without physical inspection of the goods. The export transactions had already been appraised by customs, no objection was raised to the declared value, and there was no independent evidence of undisclosed receipts or under-invoiced sales. On those facts, the marginal valuation difference was treated as a notional estimate rather than a reliable basis for income addition, and the Revenue&#039;s challenge failed.</description>
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