In that case, referring the provisions of s. 142A of the Act, has held that unless there is prima facie application under s. 69 of the Act, reference to the VO under s. 142A is simply not permissible. It is only when there is some material before the AO to hold that in case of an assessee falls under s. 69, as the case may be, that he can, to estimate the value of such unexplained investment or expenditure in bullion, jewellery, etc. and can call for the report of the valuer and therefore, the Court has observed that initial starting point for triggering a reference to the valuer, therefore, has to be invocation of s. 69 of the Act and therefore, unless and until such contingencies are reflecting on the record, reference under s. 142A of the Act cannot be resorted to. Further, it was held that the AO had no cogent material available nor to satisfy himself about the requirement of s. 69 of the Act and therefore, in the absence of it, the reference could not have been made under s. 142A of the Act. In fact, no purpose would be served to make such reference especially when the contingencies reflected hereinabove are not satisfied on the background of present facts. Therefore, considering this set of circumstance, the Court was of the opinion that the action of making reference is not tenable.