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Issues:
1. Dispute over the value of the assessee's share in agricultural land. 2. Dispute regarding the valuation of investment in the cement business. Analysis: Issue 1: Dispute over the value of the assessee's share in agricultural land The primary contention was whether the value of the assessee's share in agricultural land was correctly determined by the AAC at Rs. 40,250. The Authorised Representative for the assessee argued that the value disclosed in form No. 37G before the Registration Officer was not the fair market value, citing a previous Tribunal decision. The Tribunal agreed with the assessee, emphasizing that the value disclosed in the form was not conclusive evidence of fair market value. The authorities had relied solely on form No. 37G, lacking sufficient material to support their conclusion. Consequently, the Tribunal reversed the AAC's decision, deleting the addition made based on the disputed value. Issue 2: Dispute regarding the valuation of investment in the cement business The second issue revolved around the valuation of the assessee's investment in the cement business, initially shown at Rs. 48,500 but estimated by the ITO at Rs. 55,000 due to a lack of documentary evidence. The AAC upheld the ITO's valuation, considering it reasonable based on past assessments. The Authorised Representatives for the assessee argued that the estimate was excessive and unsupported by evidence. However, the Tribunal noted that the assessee failed to provide details of the investment, leaving the ITO to estimate the value. Despite the assessee's claim of excessiveness, no additional evidence was presented to substantiate the actual investment amount. Therefore, the Tribunal upheld the AAC's decision, finding the valuation fair and reasonable based on the available information. In conclusion, the Tribunal partly allowed the appeal, ruling in favor of the assessee on the valuation of the agricultural land share but upholding the valuation of the investment in the cement business.
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