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TMI Blog1994 (3) TMI 81X X X X Extracts X X X X X X X X Extracts X X X X ..... st of construction of the property in question to enable him to inspect and submit a valuation report of the property to the first respondent, as requested by the said officer. The petitioner states in the affidavit that during the assessment year 1986-87, having corresponding accounting year ending with March 31, 1986, whereunder the second respondent has called upon the petitioner to produce materials relating to the cost of construction of the property in question to enable him to inspect and submit a valuation report of the property to the first respondent, as requested by the said officer. The petitioner states in the affidavit that during the assessment year 1986-87, having corresponding accounting year ending with March 31, 1986, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... disabled from completing the assessment for the years 1986-87 and 1987-88 and the assessment is getting time-barred by March 31, 1994, due to non-availability of the valuation report. It is also contended that the move of the petitioner was very clever in that he has not sought for any interim orders against the completion of assessment and the mere interdiction of securing the valuation report would render the effective exercise of assessment powers virtually perfunctory. Learned counsel appearing on either side reiterated the stand as above. Mr. Janarthana Raja, learned counsel appearing for the petitioner, relied upon a Full Bench decision of the Punjab and Haryana High Court in support of his claim in this writ petition. It is seen fr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... IV, which is titled "computation of total income" and having regard to the language employed, viz., "for the purpose of this Chapter", there was no justification to confine the enabling power available under section 55A of the Act to only a limited purpose pertaining to capital gains. I am in entire agreement with the view taken by the Division Bench of the Andhra Pradesh High Court, referred to supra, and prefer to follow the same in preference to the decision of the Full Bench of the Punjab and Haryana High Court, referred to above. The plea on behalf of the petitioner that except for the purpose of capital gains for no other purpose section 55A could be availed of cannot conform to either the language or the object of the said provisi ..... X X X X Extracts X X X X X X X X Extracts X X X X
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