Pursuant to a search conducted on an erstwhile partner of the assessee-firm, the Assessing Officer initiated proceedings under section 153C and made additions towards unexplained investment based on a Departmental Valuation Officer’s report and documents seized from the former partner. The Tribunal held that neither the Assessing Officer of the searched person nor the Assessing Officer having jurisdiction over the assessee had recorded the mandatory satisfaction contemplated by section 153C. Further, no incriminating material belonging to the assessee had been found or handed over to the jurisdictional Assessing Officer. As the jurisdictional requirements of section 153C were not fulfilled, the assessment was quashed. The Revenue relied upon documents recovered from the residence of an erstwhile partner to make additions in the hands of the assessee-firm. The Tribunal held that the statutory presumption under section 292C operates only against the person from whose possession the documents are seized. Since the former partner had ceased to be a partner on the date of search and no incriminating material was found from the assessee or its existing partners, the documents could not automatically be attributed to the assessee-firm. The deletion of the additions was upheld.  The Assessing Officer made additions for alleged unexplained investment in construction solely on the basis of the Departmental Valuation Officer’s estimate without rejecting the assessee’s books of account or finding any evidence of cash investment during the search. The Tribunal held that a valuation report is merely an opinion and cannot, by itself, justify an addition under section 69B in the absence of incriminating material. The addition was deleted. The Tribunal held that adoption of CPWD rates resulted in inflated valuation. Following settled principles, it directed that appropriate rebate be granted for the difference between CPWD and State PWD rates as well as for self-supervision. After allowing these deductions, no unexplained investment survived, and the addition under section 69B was deleted.  (AY. 2016-17 to 2019-20).