u/s 56(2)(vii)(b), the addition was made based on the difference...

u/s 56(2)(vii)(b), the addition was made based on the difference between the stated value and the District Valuation Officer's (DVO) valuation. It was held that an addition cannot be made solely based on the DVO's valuation report. The land-locked issue was duly considered by both the DVO and independent valuer during property valuation. The impugned lands were land-locked properties, and the independent valuer considered the market value. The Department Representative did not submit any contrary judgment or make a strong argument against the facts cited by the assessee. After considering the different valuation reports, the independent valuer's valuation was accepted, and the land's market value was confirmed. Consequently, the addition made by the Commissioner of Income Tax (Appeals) was quashed, and the assessee's appeal was partly allowed.