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    <title>2026 (7) TMI 1382 - ITAT BANGALORE</title>
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    <description>Valuation-based additions for unexplained investment in construction under section 69B were described as unsustainable where the Departmental Valuation Officer&#039;s estimate was the sole basis, no unaccounted construction expenditure was found in search, and no material defect was identified in recorded costs; the additions were deleted. Income adopted in a section 153C assessment from a pre-search section 143(1) intimation, without any fresh addition, could not be challenged through the section 153C appeal. The prescribed remedies were appeal or rectification against the intimation, as section 153C addresses unaccounted income found in search.</description>
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      <link>https://www.taxtmi.com/caselaws?id=795496</link>
      <description>Valuation-based additions for unexplained investment in construction under section 69B were described as unsustainable where the Departmental Valuation Officer&#039;s estimate was the sole basis, no unaccounted construction expenditure was found in search, and no material defect was identified in recorded costs; the additions were deleted. Income adopted in a section 153C assessment from a pre-search section 143(1) intimation, without any fresh addition, could not be challenged through the section 153C appeal. The prescribed remedies were appeal or rectification against the intimation, as section 153C addresses unaccounted income found in search.</description>
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