Section 69B valuation dispute remanded for fresh factual verification after DVO estimate proved only indicative.

Section 69B additions based on a DVO valuation and stamp valuation were found unsupported by the CIT(A)'s arbitrary reduction to 10% of registered value, while the DVO's estimate was treated as only indicative and not conclusive. At the same time, the record showed inadequate verification by the Assessing Officer of comparable market transactions, the seller's position, and surrounding facts. The matter was therefore set aside for fresh examination by the Assessing Officer, with due opportunity to the assessee, so that the valuation dispute could be reconsidered on proper factual inquiry.

---

---

Issues: Whether the addition made under section 69B on the basis of the DVO's valuation and the stamp valuation could be sustained, or whether the matter required fresh examination by the Assessing Officer.

Analysis: The purchase was reflected at a lower consideration, while the stamp authority's valuation and the DVO's estimate were higher. The Tribunal held that the assessee's explanation did not satisfactorily account for the difference, and that the CIT(A)'s reduction of the addition to 10% of the registered value had no basis. At the same time, it found that the Assessing Officer had not properly verified comparable market transactions, the seller's position, or other surrounding facts, and that the DVO's estimate by itself was only indicative and not conclusive.

Conclusion: The issue was set aside and remanded to the Assessing Officer for fresh consideration after giving the assessee due opportunity.

---