ITO v. Pritham & Prathik Hospitals (P) Ltd (2023) 221 TTJ 911/223 DTR 177 (Hyd)(Trib)

S. 69: Unexplained investments-Difference in Cost of Construction as per valuation Report-Books of account not rejected-Addition is not justified. [S. 142A(2)]

AO noticed that there is discrepancy in the cost of construction and investment recorded in books of accounts. The AO referred the matter to DVO and thus added the difference of Rs.64.10 lacs. AO had not doubted the cost of construction recorded in the Books. The AO has not brought any material on record to establish that the appellant had made any unaccounted investment in the construction of the building in question. It was held that without rejecting the books of accounts, it is not open for the Assessing Officer to refer the matter to Valuation Cell for determining different entries and the expenditure incurred by the assessee. (AY. 2014-15)