Assessee, a constituent unit of CSIR, claimed that valuation of perquisites for rent-free or concessional rent accommodations provided to its employees should be computed under Rule 3 considering its employees at par with Central Government employees. Lower authorities rejected said claim. On appeal, High Court held that for purposes of Rule 3, requirement is that accommodation should be provided by Central Government or State Government to employees either holding office or post in connection with affairs of Union or of State or serving with any body or undertaking under control of such government from deputation. It was further observed that aforesaid expression is unambiguous and unclear and therefore, its meaning could not be expanded to include any body, undertaking under control of Central Government and merely because assessee was a body or undertaking owned or controlled by the Central Government, it could not be elevated to status of Central Government and therefore, assessee could not claim that valuation of perquisites in respect of residential accommodation should be computed as in case of an accommodation provided by Central Government.  Therefore, Sl.No.1 of Table 1 of Rule 3 of Rules would not apply to assessee-However, High Court held that proceedings under Sections 201 and 201(1A) were to be quashed, as assessee had made a bona fide estimate of perquisite value consistent with a similar ruling for another CSIR unit. SLP of Revenue is dismissed.  there was no reason to interfere with order of High Court and therefore, Special Leave Petitions were to be dismissed.  (AY. 2007-08 to 2011-12)