Addition made u/s 69 on the basis of DVO’s report which itself is found to be defective deserves to be deleted:

Assessee purchased a piece of land and sold it subsequently. AO referred the matter to DVO (Departmental Valuation Officer) for valuation and made an addition u/s 69 on the basis of such valuation. On appeal, CIT(A) found that DVO’s report had many defects. DVO had not taken proper comparables for the purpose of valuation. DVO had taken into account constructed property whereas what was sold by the assessee was and open piece of land. Since the AO had blindly followed DVO’s report and there was no evidence on record to prove that the consideration was actually higher than what was reflected by the assessee, CIT(A) deleted the said addition. CIT(A) also opined that provisions of S.50C would have application only for the purpose of determining the sale consideration for computing capital gain. S.50C can’t be applied for determining income under other heads of income. The said was upheld by the Tribunal as well as the Hon’ble High Court. Revenue’s appeal was dismissed accordingly.

[CIT Vs. SHILANKIT ARCADE (P.) LTD. - TAX APPEAL NO.420 of 2011 – GHC]