2021 (7) TMI 941

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....R Per S. S. Godara , JM This assessee's appeal for AY. 2003-04 arises from the CIT(A)-10, Hyderabad's order dated 17-06-2016 passed in appeal No. 0329/CIT(A)-10/2015-16, involving proceedings u/s. 143(3)r.w.s. 263 of the Income Tax Act, 1961 [in short, 'the Act']. Heard both the parties. Case file perused. 2. The assessee has pleaded the following substantive grounds in....

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....ned CIT(A) ought to have seen that neither the Valuation Cell nor the Assessing Officer have given relief towards rate difference between the CPWD and PWD and allowed a deduction of 15% of the cost. 6) The learned CIT(A) ought to have seen that deduction on account of self supervision is 10% and not 6% as allowed by the Valuation Cell. 7) The learned CIT(A) ought to have seen tha....

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....ddition of Rs. 16,09,048/- on account of the alleged difference between the department's valuation cell as against the books of accounts maintained at the taxpayer's behest. Learned counsel sought to invite our attention to various distinguished features adopted by the valuation cell viz-a-viz assessee's books of account, CPWD and the said state PWD rates as well as the necessary adjus....

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....h the lower authorities' action making the impugned cost of construction addition. 7. We have given our thoughtful consideration to rival contentions against and in support of the impugned addition amounting to Rs. 16,09,048/-. Case file prima facie suggests that neither the valuation cell nor the learned lower authorities have taken into consideration the alleged difference between the sta....