Tax Department Must Prove Undisclosed Income in Property Deals; Market Value Can't Replace Deed Without Evidence.

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....Undisclosed incomes - investment in Purchase/sale of immovable property - The onus on the department to prove that investment was made by Assessees or sale consideration received by the Assessee, as the case may be was in fact more than that depicted in the sale deed did not get discharged at all. CIT (A) has rightly held that ld. AO cannot substitute the apparent consideration mentioned in the sale deed so as to adopt the market value without bringing any material on record to show that consideration disclosed in the sale deed is in excess of the value adopted by the assessee - AT....