9911796707
TMI Blog1986 (11) TMI 138X X X X Extracts X X X X X X X X Extracts X X X X ..... is made on account of cost of construction. The plea of the assessee was that the assessee had constructed a factory building within a period of over three years at a cost of Rs. 3,30,831. The matter was referred to the Valuation Officer who had valued it originally at over 6 lacs and after repeated objections raised had ultimately determined the value at Rs. 4,26,682. The Department has treated ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... items like, the extra electrical connection which in fact was borne by the Electricity Board, this resulting in un-necessary counting it in the hands of the assessee. He also submitted that in the quantity of steel though the departmental valuer had taken the figure to be 17,925 Kgs. while the actual quantity used by the assessee was 14,746 Kgs. The approved valuer of the assessee was satisfied th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ld not have allowed any reduction in view of the departmental valuer's report. 2. We have given very careful consideration to the arguments of the parties. At the out set, we must observe that in para 3 of the ITO has observed that between the dates of 12th Sept., 1981 to 1st Oct., 1981 the cash book was not written up properly and the debits being more than the credits and ultimately the assesse ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the case as well as the rate of difference on account of schedule of rates of PWD and CPWD, we estimate the cost of construction at Rs. 3,75,000. The ITO is directed to treat the difference between the cost as shown by the assessee in his books and Rs. 3,75,000 and distribute the same unexplained over the period of construction of three years in the proportion of the cost shown to have been incur ..... X X X X Extracts X X X X X X X X Extracts X X X X
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