Stamp duty valuation cannot prove extra sale consideration without independent evidence, and the addition was unsustainable.

Section 50C deems stamp duty value only for capital gains computation and does not, by itself, prove that more consideration actually passed between the parties. The Revenue had to produce positive evidence before treating the disclosed sale price as suppressed or before sustaining an addition for unexplained investment under Section 69B. As the record showed the appellate authority had examined the material and accepted the disclosed consideration, the request for a valuation reference under Section 142A did not justify interference. The addition was held unsustainable, the principle of consistency was applied, and no substantial question of law arose.

---

---

Issues: Whether the value adopted by the State authority for stamp duty purposes could, in the absence of independent evidence, be treated as the actual sale consideration or the basis for adding unexplained investment, and whether any substantial question of law arose from the Tribunal's affirmance of the deletion of the addition.

Analysis: The statutory scheme under Section 50C of the Income-tax Act, 1961 creates a deeming fiction for the limited purpose of computing capital gains and does not, by itself, establish that more consideration passed between the parties. The burden remained on the Assessing Officer to produce positive evidence that the assessee had paid more than the consideration disclosed in the sale deed. The record showed that the appellate authority had examined the material, obtained comments from the Assessing Officer, and accepted the disclosed consideration as proved. In these circumstances, the request to require a reference to the Valuation Officer under Section 142A of the Income-tax Act, 1961 did not warrant interference, and the addition under Section 69B of the Income-tax Act, 1961 was unsupported by evidence. The appellate view also accorded with the principle of consistency.

Conclusion: The addition was not sustainable, and no substantial question of law arose for admission of the Revenue's appeal.

Final Conclusion: The appeal failed at the threshold, and the deletion of the addition was left undisturbed.

Ratio Decidendi: A stamp duty valuation under Section 50C of the Income-tax Act, 1961 cannot, without independent evidence, be treated as proof of actual consideration or unexplained investment.

---