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Issues: Whether the original value of investment in plant and machinery exceeded the prescribed limit so as to deny eligibility under the Compounded Levy Scheme, and whether the adjudicating authority could reject the Chartered Accountant's certification and determine the valuation on its own.
Analysis: The valuation requirement under Rule 96ZNB(1) contemplated a declaration certified by a Chartered Accountant or Cost Accountant. The later notifications and the explanation regarding Accounting Standard 10 were treated as clarificatory and applicable to the scheme. In the absence of any contrary expert opinion, the adjudicating authority could not disregard the Chartered Accountant's certificate and substitute its own estimate based on presumptions or best judgment. The statutory scheme required the valuation to rest on expert certification, not on unilateral departmental reassessment.
Conclusion: The rejection of the Chartered Accountant's valuation was unjustified, and the finding that the original value exceeded three crore rupees could not be sustained. The assessee was entitled to the benefit of the Compounded Levy Scheme.