9911796707
TMI Blog1977 (4) TMI 74X X X X Extracts X X X X X X X X Extracts X X X X ..... estimate the cost of remodelling at Rs. 59,000. It was contended before the ITO that remodelling was done for Rs. 25,000 in asst. yr. 1971-72 and for Rs. 15,000 in asst. yr. 1972-73 and the actual amount spent by him was only Rs. 40,000. The ITO did not accept the contention. Accepting the valuation estimated by the Asstt. Valuation Officer, the ITO concluded that the cost of remodelling was of th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... edule of rates, which include contractor s profit and deduction for personal supervision of the work by the appellant and the purchase of old materials had not been taken into account for estimating the cost of remodelling and if these factors are taken into account, the gap in the unexplained cost of remodelling will be considerably narrowed. 4. The learned Departmental representative mainly re ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rch, 1971 and after 31st March, 1972. In the circumstances, it is difficult to apportion the addition to be made for the understatement of cost of construction between the two years." The above finding of the AAC clearly lends support to the plea of the appellant that remodelling was done during the period of two assessment years and the AAC found it difficult to apportion it. The books of accou ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... partment and purchased as second hand material. These aspects have not been taken into account by the Departmental valuer. Moreover, the Departmental valuer has added 5 per cent towards supervision charges, handling of materials, etc. As the remodelling was done under the personal supervision of the appellant, there is absolutely no basis for the additional made under this head. Houses at Nos. 26, ..... X X X X Extracts X X X X X X X X Extracts X X X X
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