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1984 (8) TMI 152

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..... ements and additions to an existing property at 56, Madurai Road, Triohy. In the absence of accounts, the assessee estimated the cost of construction at Rs. 20,808/-and supported it by a Valuer s report. Noting that the assessee had originally given another report by the same Valuer estimating the costs of construction at Rs. 37,370 the ITO made an addition of Rs. 21,000 as unexplained investment .....

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..... s sustained only on the basis of an estimate of the cost of construction which does not conclusively prove that the amount added was in fact the income of the assessee, especially when there has been large difference of opinion between the estimates of the Valuer and the estimates made by the taxing authorities at different stages. In the circumstances, we agree with the AAC that the penalty impos .....

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