During the course of assessment proceedings, the valuation of buildings of various institutions of the assessee was referred to the valuation cell. The assessee was confronted with the report of the Valuation Officer. Since the Valuation Officer had worked out the difference of Rs. 4,03,72,178 up to the assessment year 2013-14 in his report, the Assessing Officer added the difference in the assessment year 2013-14 under S. 69B . The CIT (A) deleted the addition as the difference between the actual investment, shown by the assessee and estimated by the Valuation Officer was only 9.86 per cent. which was less than 15 per cent. On appeal the Tribunal held that  the Department could not controvert the factual findings. Hence, the addition made on account of the difference of the investment and as estimated by the Valuation Officer being less than 15 per cent. the addition was deleted.( AY.2009-10 to 2015-16)