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(xi) On the facts and circumstances of the case, the learned CIT(A) has erred both on facts and in law in estimating the cost of bio matrix at Rs.3 Lac,

(xii) On the facts and circumstances of the case, the learned CIT(A) has erred both on facts and in law in estimating the cost of lift at Rs.8 Lac.

(xiii) On the facts and circumstances of the case, the learned CIT(A) has erred both on facts and in law in estimating the cost of discotheque at Rs.5 Lac.

* Have you seen house with Biomatrix central locking system with Touch Screen Facility operated jay only four members of the House?
* Have you seen a house) with lush green lawn, landscape designed by famous landscape artist Smt. Geeta Singh running into 4 ½ Kanals having beautiful gardens, elegant parking place and a green paradise?
* Have you seen a house with gym with modern training equipment, bar, swimming pool, discotheque, Jacuzzi, steam bath, massage parlour, billiard rooms and a splendid terrace garden full of beautiful flowers as well as plants- yellow allemandes, petunia, marigold and phoenix palms?

10. Landscaping on entire area of 4 ½ kanals, parking area, main 35,00,000/-

gates, green paradise, greeneries, plants on the roof top etc. ITA 722,723,725,726/CHD/2013 & ITA 586 to 590/CHD/2013

11. Billiards Room with Billiard sticks. 15,00,000/- 

12'      Biomatrix lock system                                                                  25,00,000/-
13       Lift                                                                                   10,00,000/-
14       Discotheque along with lights, floors etc.                                             25,00,000/-
TOTAL                                                                                           22,32,50,000/-
     LS_signifies_Lump sum

conditioning system; the fittings including GD sets; the gymnasium; the swimming pool; landscaping; biometric system; paintings and murals; lifts; discotheque etc., the cost has been taken on lump sum basis. Reliance for assessing the cost of construction and cost of furnishing on best judgement basis were drawn from Dr. S. Surendranath Reddy Vs. AC1T (2000) 72 1TD 205 (Hyd); the decision of the Hon'ble Supreme Court in the case of CST Vs H.M. Esufali H.M. Addulali[1973] 90 1TR 271, CIT Vs, Laxminarain Badrid;is (1937) 5 ITR 170 (PC) and Raghubar Mandal Harihar Manda! vs. State of Bihar (1957) 8 STC 770(SC). Consequently the total investment in the house was worked out to Rs. 22,32,50,000/- as against the sum of Rs. 2,23,92,37S/-declared by the assessee. The unaccounted investment of Rs. 20,08,57,625/-, after deducting the cost declared by the assessee, was added u/s 69B, which was apportioned year-wise as under: