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Valuation by DVO - addition based on estimated cost disregarding actual cost as per books - applicability of section 142A before amendment - non-rejection of books - AO alleged WIP suppressed and engineer's certificate unreliable - referred to DVO for valuation - held that AO must first express dissatisfaction with books before referring valuation - rejection of books requires specific reasons and evidence of discrepancies - addition based on estimated value without contradicting actual cost is unjustified - estimation exercise based on average gross profit rate is improper without rejecting books - AO must adhere to section 145(3) before assessment u/s 144 - valuer clarified not withdrawing certificate, not considered by AO/CIT(A) - addition based on estimated cost without discrediting actual cost is not justifiable - assessee's appeal allowed.
Valuation by DVO - addition based on estimated cost disregarding actual cost as per books - applicability of section 142A before amendment - non-rejection of books - AO alleged WIP suppressed and engineer's certificate unreliable - referred to DVO for valuation - held that AO must first express dissatisfaction with books before referring valuation - rejection of books requires specific reasons and evidence of discrepancies - addition based on estimated value without contradicting actual cost is unjustified - estimation exercise based on average gross profit rate is improper without rejecting books - AO must adhere to section 145(3) before assessment u/s 144 - valuer clarified not withdrawing certificate, not considered by AO/CIT(A) - addition based on estimated cost without discrediting actual cost is not justifiable - assessee's appeal allowed.
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