Valuation reference used to extend assessment limitation was invalid where no genuine asset valuation inquiry was required.

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....Reference to a Valuation Officer for a company's fixed assets immediately before expiry of the assessment period was treated as an impermissible attempt to extend the completion deadline. A valuation was unnecessary to examine an alleged bogus depreciation claim because it could be disallowed on the available material. Nor was a genuine valuation required for alleged unaccounted payments: asset-related material and explanations were already on record, later show-cause notices did not question asset valuation, and no satisfactory reason was given for earlier inaction. The reference was characterised as a colourable and illegal use of power to invoke time exclusion, and was quashed.....