I have had benefit of going through order of my ld. brother and though I have no difference as far as conclusion arrived at is concerned, I would, however, like to add my own views on matter. In instant case, facts go to indicate that assessee has not maintained any account in respect of construction of properties. assessee had only made effort of showing cost on basis of what has been withdrawn by him from firms books and he has tried to support aggregate drawing by means of report from approved valuer. approved valuer in his very detailed report observed certain principles of valuation. He referred to view expressed by eminent writer on valuation of properties Roshan Nanawati "of various methods of estimating cost of construction of building, namely, itemwise estimate, cube, plinth area unit basis, cost index, results obtained by itemwise estimate are most accurate cost." departmental valuer had taken mean period in respect of two properties and arrived at valuation, which valuation is sketchy one. In absence of information of stages of construction as well as period during which such construction took place valuation officer of Department have no alternative but to take mean period. However, since figures of prices of materials, which are used in building constructions are available on various dates, he could have brought price of such materials as was existing on various dates to justify that mean value taken by him is reasonable and correct one. problem in this kind of valuation is one of fact of accuracy. It has tendency to take into account certain items as cost which may have no relation at all, for example, material price which are required upto level of plinth, roofing which might have been completed much before mean period would also necessarily bear increase which is made on percentage basis from mean period to ultimate date of completion. There could be argument that this kind of increase evens out or spreads uniformly as actual increases are not taken into account and this may not result in excessive addition. I do realise limitations of departmental valuer but at same time would have preferred if he was in position to deal item by item as was dealt by approved valuer, which to my mind, would be better objective proposition. Unfortunately, even assessee has not tried this exercise but rather has only objected to certain additions made on percentage basis. assessee would have had ker case had he maintained proper books of accounts in respect of construction activity. At same time this does not mean that addition has to be necessarily made merely because departmental valuer had estimated at higher figure. ITO had no alternative but to seek opinion of expert, namely, departmental valuer, as he had no means of examining correctness or otherwise of cost of construction declared by assessee and which has been approved by approved valuer. Once having resorted to departmental valuer's opinion and giving opportunity to assessee appears to be in proper perspective. In these circumstances, ITO is perhaps left with no other option but to weigh two valuation reports and to come to decision as to which one of them should be accepted, which could be near-about actual figures. In instant case as already pointed out, assessee has only objected to certain additions made on percentage basis did not at all raise objection to adhocism in valuation. percentage which are used is on some kind of rough basis or it could be said that it is expected that normal building will have so much of electrical fittings so much of sanitary fittings and like. Similarly, he has asked for deduction on account of personal supervision etc., and all these objections appear to be some kind of haggling activity. On whole primarily assessee would have felt satisfied if some of his demands are accepted as assessee is not in position to stand up and claim that his figures cannot be disturbed. In this situation when assessee is not able to establish that cost as shown by him is correct and cannot be disturbed which on fact of if appears to be wrong then probably placing reliance on departmental valuer report, cannot be said to be altogether wrong. Last but not least, to make on addition merely based on valuer's report to my mind, is just not at all proper, as it can in no way be treated to indicate additional investment made by assessee but businessmen who are known to invest more in buildings from their uncounted moneys cannot possibly be checked but for this round about route adopted by Department especially in cases where no books of account are maintained. *** INCOME TAX OFFICER v. OMPRAKASH & ORS