Valuation evidence in construction cost disputes favours contemporaneous registered valuer reports over later departmental estimates.

Estimated cost of construction addition was rejected because the registered valuer's certificate, being closer to the construction period, was treated as better evidence of actual cost than the later Government valuer's report. The Board's circular was also relied on to support a non-burdensome approach in valuation matters involving smaller assessees. The addition was therefore not justified and was not sustained.

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Issues: Whether the addition made on account of the estimated cost of construction was justified, and whether the registered valuer's report should prevail over the later Government valuer's report.

Analysis: The registered valuer's certificate was closer to the relevant construction period and therefore provided better guidance on the actual cost of construction. The Board's circular was also relied upon to indicate that departmental action should not unnecessarily burden smaller assessees in valuation matters.

Conclusion: The addition was not justified and was not sustained.

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