Marginal DVO valuation difference was held insufficient to disturb the Tribunal's rejection of the addition.

A marginal variation between the assessee's declared construction cost and the Departmental Valuation Officer's valuation was held insufficient to justify interference, as the difference was only 2.54%. Following the earlier Division Bench ruling in Ambience Developers, the Delhi HC held that no substantial question of law arose and the Tribunal was justified in refusing to sustain the addition. The Tribunal's order was left undisturbed and the appeal was dismissed.

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Issues: Whether the Tribunal was justified in refusing to sustain the addition based on the Departmental Valuation Officer's report where the variation between the assessee's declared construction cost and the DVO valuation was only 2.54%.

Analysis: The variation between the assessee's valuation and the DVO's valuation was found to be minimal. Relying on the earlier Division Bench ruling in Ambience Developers, the Court held that such a marginal difference does not justify interference, and no substantial question of law arose for consideration.

Conclusion: The appeal was dismissed and the Tribunal's order was left undisturbed.

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