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TMI Blog2017 (3) TMI 743X X X X Extracts X X X X X X X X Extracts X X X X ..... constructed over 900 Sq.Ft. As per the decision of collector of stamps, the construction has been valued at ₹ 12,66,056/- as on 27.03.2012 while determining the value for stamp valuation. Also the assessee has submitted the individual balance sheet as on 30.03.2010 wherein the construction for ₹ 2,45,855/- (for indexed cost of improvement of ₹ 2,76,587/-) has been shown. In view of above facts, apparently the assessee has demolished the original construction and made the new construction thereon as per the facts stated above. Accordingly the addition made by the AO to be deleted. - D.B. Income Tax Appeal No. 291 / 2016 - - - Dated:- 8-3-2017 - Ajay Rastogi And Kailash Chandra Sharma, JJ. For Appellant : Mr.N.L.Aga ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... factual matrix on record expressed its opinion ad infra:- 5.3 I have considered the contentions of the appellant as well as assessment order. It is seen that the AO has not allowed the cost of construction of ₹ 2,45,000/- as per the revised return filed by the assessee on 14.07.2012 stating that no bills/vouchers for purchase of material for construction purposes were submitted. However it is evident from the purchase deed that constructed area at the time of purchase on 27.03.2003 was 146.31 Sq.Mtrs. Consisting of five rooms, kitchen, garage, store, bathroom and toilet. However as per the sale deed dated 23.02.2011, the old construction was demolished and RCC pillars were constructed over 900 Sq.Ft. As per the decision of col ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e assessee s letter dated 30.03.2011 relating to unrecorded purchase bills at the time of survey and expenses in the books of accounts, excess valuation of the stock etc., compared it with the position in the return of income, taken into consideration the remand report of the AO and gone through each of the contentions raised by the ld AR along with the rejoinder to the remand report in terms of unrecorded purchases, valuation, set off etc and has come to a well-reasoned decision. We see no reason to interfere with the order of ld CIT(A) and the same is hereby confirmed. Counsel for the appellant submits that the statement which has been recorded u/Sec.133-A of the Act, 1961 has no evidentiary value and there is a difference between t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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