2005 (11) TMI 58

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....es of the assessee did not lead to the seizure of any incriminating evidence to suggest that any income had not been disclosed or would not have been disclosed for tax purpose under the Income-tax Act, 1961. It has, on that finding, held that the Assessing Officer was not justified in making additions on the basis of the report of the Valuation Officer in regard to two of the properties purchased ....

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....ntained code and no addition can be made on the basis of the DVO's report when no evidence has been found during the course of search to establish that the assessee has paid more than the disclosed consideration in purchase of the properties or construction thereof or that it has received sale consideration more than disclosed in the regular accounts maintained by him or return of income filed in ....