Held that under section 142A a reference can be made to ascertain the value of any investment referred to in section 69 or section 69B or the value of any bullion, jewellery or any other valuable article referred to in section 69A or section 69B of the Act. There is conspicuous exclusion of section 69C. The reference under section 142A in the assessee’s case had not been made for ascertaining the correct market value of the investment in property but for the purpose of ascertaining the expenditure which the assessee had made on the purchases. The reference to the Departmental Valuation Officer under section 142A for the purpose of section 69C was not valid. Held that  under section 250 of the Act, the Commissioner (Appeals) is empowered to make further inquiry as he thinks fit or direct the Assessing Officer to make further inquiry and report to him. Under section 251(1)(a), in appeal against an order of assessment, he may confirm, reduce, enhance or annul the assessment, but there is no such power to change the provision of law qua the item of which assessment was made. Therefore, in the absence of such power, the Commissioner (Appeals) could not have treated the addition made under section 69C as an addition made under section 69B. There was no power conferred upon the Commissioner (Appeals) to assess a particular item under a different provision of the Act than the Assessing Officer had done without giving specific notice to the assessee regarding such action The addition made under section 69C on the basis of the report of the Departmental Valuation Officer by the Assessing Officer was to be deleted.(AY.2006-07)