Held that the addition is  made on the estimated value, without substantial evidence to contradict the actual cost recorded by the assessee, which was not justifiable. That  the District Valuation Officer had submitted a letter clarifying that he had not withdrawn the certificate and its correctness should not be doubted. Neither the Assessing Officer nor the Commissioner (Appeals) had taken into consideration this letter by the valuer which was a basis for referring the valuation to the District Valuation Officer. The addition based on the estimated cost, without discrediting the actual costs recorded, is  not justifiable. (AY.2013-14, 2014-15)