Cost of construction is a factual question; tribunal may adopt PWD rates based on case-specific construction evidence.

Cost of construction for income-tax purposes is primarily a question of fact, depending on the material used, the location and the quality of construction. The text states that no uniform rule requires adoption of either PWD rates or CPWD rates in every case. On the facts discussed, the Tribunal's use of Rajasthan PWD rates was treated as part of its factual finding, and the issue was answered in favour of the assessee and against the Revenue.

---

---

Issues: Whether, for determining the cost of construction of a house property for income-tax purposes, the Tribunal was justified in adopting Rajasthan PWD rates instead of CPWD rates.

Analysis: The cost of construction is primarily a question of fact depending on the material used, the location, and the quality of construction. A uniform rule requiring application of either PWD rates or CPWD rates in every case is not justified. On the facts of the case, the Tribunal's adoption of PWD rates formed part of its factual finding.

Conclusion: The question was answered in the affirmative, in favour of the assessee and against the Revenue.

---