Taxpayer Challenges Property Valuation u/s 56(2)(vii)(b); Corrective Measures Allowed for Valuation Discrepancies.

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....Unexplained income u/s 56(2)(vii)(b) - amount by which an immovable property purchased by the assessee fell short of its stamp duty value - The contention of the AO is bound to accept the DVO’s report, we agree with the same. But at the same time Valuation of property is only an exercise in approximate estimation. And therefore there is always scope for correction of the estimates on account of discrepancies. Assessee is well within his rights to contest the valuation, which if found justified, the appellate authorities cannot shut their eyes to the same. - AT....