Stamp valuation and section 54F exemption depend on statutory conditions, not a belated return or separate stamp-law objections.

Stamp valuation adopted under the stamp law may be relied on in income-tax assessment proceedings, and an assessee's objection that the valuation process was separate and not heard there cannot defeat section 50C. For section 54F, belated filing of the return does not by itself affect substantive entitlement where the entire sale consideration is invested in a new residential house within the prescribed period. Failure to deposit the unutilised amount in the Capital Gains Account Scheme does not deny exemption when the statutory investment condition is otherwise satisfied.

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Issues: (i) Whether the value adopted by the stamp valuation authority for the transferred property could be relied upon in the income-tax proceedings and whether the assessee's objection to such valuation could defeat the application of section 50C; (ii) Whether the assessee was entitled to exemption under section 54F despite the return being filed belatedly and without deposit of the unutilized amount in the Capital Gains Account Scheme when the entire sale consideration was invested in the new residential house within the prescribed period.

Issue (i): Whether the value adopted by the stamp valuation authority for the transferred property could be relied upon in the income-tax proceedings and whether the assessee's objection to such valuation could defeat the application of section 50C.

Analysis: The valuation fixed by the District Revenue Officer for stamp duty purposes was treated as binding in the income-tax proceedings. The objection that the assessee was not heard in the stamp proceedings was held to be untenable because the stamp valuation proceedings were separate and independent, and any grievance against that valuation had to be pursued before the appropriate forum under the stamp law. The challenge to the adopted value in the assessment proceedings was therefore rejected.

Conclusion: The adopted stamp valuation was upheld and the assessee's objection failed.

Issue (ii): Whether the assessee was entitled to exemption under section 54F despite the return being filed belatedly and without deposit of the unutilized amount in the Capital Gains Account Scheme when the entire sale consideration was invested in the new residential house within the prescribed period.

Analysis: The delay in filing the return was held to have no bearing on the substantive entitlement to exemption under the Act. It was further found as a fact that the entire capital gain amount had been invested in the construction of a new residential house within the time contemplated by section 54F. Since the investment was completed within the prescribed period, the absence of a deposit in the Capital Gains Account Scheme did not defeat the exemption claim.

Conclusion: The assessee was entitled to the benefit of section 54F and the Revenue's challenge failed.

Final Conclusion: The order of the first appellate authority was sustained, and both appeals were rejected as without merit.

Ratio Decidendi: A stamp valuation fixed under the stamp law can be relied upon in income-tax assessment proceedings, and exemption under section 54F depends on timely investment in the new residential house rather than on the mere filing delay of the return where the statutory investment condition is satisfied.

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