1981 (2) TMI 116

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....79,881 for the purpose of additions, alterations and providing furniture and fixtures to the extended portion. These withdrawals had been made over a period of three years as the property was constructed between December, 1974 and December, 1976. The withdrawals made year-wise were as under: Asst. yr. 1975-76 Rs. 19,900 Asst. yr. 1976-77 Rs. 54,406 Asst. yr. 1977-78 Rs. 5,575 The assessee has further placed before the ITO a report of the registered value M/s H.P. Kuchhal & Co. Who had given the valuation after inspecting the building on 19th Jan., 1977. According to the valuer's report the value of the addition and alteration was about Rs. 68,000 after considering the probable saving of 10 per cent due to perso....

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....tter came before the ITO (A) he confirmed the addition made by the ITO as he found that there was no record for the construction and there were no details about the expenses on furniture and furnishings. 5. It has been submitted before us by the ld. counsel for the assessee that the addition made on the basis of the report of the registered valuer was not proper as the report had not been made available to the assessee. He further submitted that the report of the registered valuer who has been appointed by the Board should not have been rejected as there was very much detailed and it was based on the rates approved by the Rajasthan PWD. It was further submitted that the assessee had not engaged any architect and the whole additions and a....

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....een placed before us. We have, however, looked into the various points of difference as pointed out by the ITO and the CIT (A). After looking into the differences we find that the Valuation Officer has not given any deduction for personal supervision by the assessee himself. The Valuation Officer has also taken into consideration the expenses on architect's fees and builder's efforts in supervision and over-head. As the additions and alterations have been made under the personal supervision and it was not given to any contractor, some consideration has to be allowed for that factor. If we proceed on the basis of the report of the Valuation Officer and keep the above consideration in view, the approximate cost of consideration to the assesse....