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2024 (4) TMI 448

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....R PER N.K. BILLAIYA, ACCOUNTANT MEMBER:- This appeal by the Revenue is preferred against the order of the ld. CIT(A) - 1 New Delhi, dated 20.07.2017 pertaining to A.Y. 2013-14. 2. The grievances of the Revenue read as under: "1. The Ld. CIT(A) has erred in law and on facts in holding in the beginning of his order that the addition made of Rs. 2,98,61,649/- was not justified without appreciati....

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....on facts in deleting the addition of Rs. 1,65,39,595/- made by the AO on account of unexplained investment u/s 69 of the Income-tax Act, 1961 in the construction of building without appreciating the facts brought on record by AO. 4. The Ld.CIT(A) has erred in law and on facts in deleting the addition of Rs. 33,41,966/- made by the AO on account of notional rental income. 5. The Ld. CIT(A) has ....

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....item of this addition is addition of Rs. 1,65,39,595/- on account of unexplained investment. 5. We find that the Assessing Officer has made the addition on the basis of market price of the land and building whereas the assessee has declared the value of these assets as per cost incurred by it when the land was purchased in F.Y. 2010-11. 6. The basis of the addition is the valuation report submit....

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....be 8% per annum on total investment made by the assessee on construction of second building which included all fixtures and other assets in proportion to the area handed over. 9. The assessee has returned rental income as per this sub-lease deed. However, when the valuation report was submitted during the assessment proceedings, the Assessing Officer found that market value of the constructed pro....