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    <title>2023 (12) TMI 1511 - ITAT INDORE</title>
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    <description>Before section 142A(2) took effect on 1 October 2014, a reference to the Departmental Valuation Officer for estimating undisclosed construction investment required prior rejection of the assessee&#039;s books of account. Where the books were not rejected, the valuation reference and resulting report could not support additions for unexplained investment under section 69B; the valuation-based additions were therefore unsustainable. Grounds concerning valuation and related claims, left undecided as academic after deletion of the additions, required merits adjudication after affording opportunity. The deletion remained sustained, while unresolved grounds were restored to the appellate authority for decision on merits.</description>
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      <title>2023 (12) TMI 1511 - ITAT INDORE</title>
      <link>https://www.taxtmi.com/caselaws?id=471016</link>
      <description>Before section 142A(2) took effect on 1 October 2014, a reference to the Departmental Valuation Officer for estimating undisclosed construction investment required prior rejection of the assessee&#039;s books of account. Where the books were not rejected, the valuation reference and resulting report could not support additions for unexplained investment under section 69B; the valuation-based additions were therefore unsustainable. Grounds concerning valuation and related claims, left undecided as academic after deletion of the additions, required merits adjudication after affording opportunity. The deletion remained sustained, while unresolved grounds were restored to the appellate authority for decision on merits.</description>
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