1986 (8) TMI 148

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....usion arrived at is concerned, I would, however, like to add my own views on the matter. 2. In the instant case, the facts go to indicate that the assessee has not maintained any account in respect of construction of the properties. The assessee had only made the effort of showing the cost on the basis of what has been withdrawn by him from the firms books and he has tried to support the aggreg....

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....take the mean period. However, since the figures of prices of materials, which are used in building constructions are available on various dates, he could have brought price of such materials as was existing on the various dates to justify that the mean value taken by him is reasonable and correct one. The problem in this kind of valuation is one of fact of accuracy. It has a tendency to take into....

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....s not tried this exercise but rather has only objected to certain additions made on a percentage basis. The assessee would have had a stronger case had he maintained proper books of accounts in respect of the construction activity. At the same time this does not mean that an addition has to be necessarily made merely because a departmental valuer had estimated at a higher figure. The ITO had no al....

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....The percentage which are used is on a some kind of rough basis or it could be said that it is expected that a normal building will have so much of electrical fittings so much of sanitary fittings and the like. Similarly, he has asked for deduction on account of personal supervision etc., and all these objections appear to be some kind of haggling activity. On the whole primarily the assessee would....