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2021 (2) TMI 132 - AT - Income TaxRevision u/s 263 - Non verification of reason for filing the second valuation report by assessee - AO did not apply his mind so as to properly verify and examine the two valuation reports submitted by the assessee during the course of assessment proceedings and passed the assessment order relying upon the valuation report in which the fair market value of the building cost of the property is shown at ₹ 1,02,61,710/- - HELD THAT:- We have carefully perused the valuation report placed on record in the form of paper book. Undoubtedly the valuation report dated 15.12.2012 has valued the property as on 15.12.2012 whereas the assessment year under consideration is A.Y.2010-11 relevant to F.Y.2009-10. As the construction had completed on 31.03.2010 the assessee correctly got the second valuation report dated 15.12.2012 valuing the property as on 31.03.2010. These facts were very much available during the course of the scrutiny assessment proceedings itself and also before the Pr. CIT for proceedings u/s.263 of the Act. We find that the AO has correctly accepted the correct valuation report and completed the assessment. As seen from the assessment order that the AO had made enquiries in respect of the cost of construction and it cannot be said that no query was raised by the AO in respect of the cost of construction. In our considered opinion it is not open to enquire in case of inadequate enquiry. Infact in the case in hand the facts clearly show that adequate enquiries were made by the AO which were duly replied by the assessee. We find that the AO has taken one of the plausible view and the Pr. CIT cannot substitute his view with that of the AO - Decided in favour of assessee.
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