Section 50C stamp duty value alone cannot prove understatement of sale consideration without objective supporting material.

Stamp duty value under Section 50C is only a starting point for inquiry and, by itself, does not establish understatement of sale consideration. An addition cannot be sustained unless the Revenue relies on objective material and relevant facts showing that the declared consideration is not the actual consideration received. Contemporaneous sale deeds and valuation material cannot be ignored merely because the government valuation is higher, and the Assessing Officer must undertake proper inquiry before making the addition. The principle is that Section 50C valuation alone is insufficient without supporting evidence of understatement.

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Issues: Whether the Revenue could sustain an addition merely on the basis of stamp duty value under Section 50C without relying on objective material showing understatement of consideration.

Analysis: The Court applied the settled principle that the stamp duty value may be a starting point for inquiry, but it cannot by itself establish understatement of sale consideration. The Revenue must rely on objective facts and circumstances, and the assessee's contemporaneous sale deeds and valuation material could not be ignored on a bare preference for the government valuation. The Court also noted that the Assessing Officer had not disturbed the declared purchase value and had not undertaken the necessary inquiry to justify the addition.

Conclusion: The issue was answered against the Revenue and in favour of the assessee; Section 50C value alone could not support the addition.

Ratio Decidendi: Stamp duty valuation under Section 50C cannot, by itself, prove understatement of consideration unless supported by objective material showing that the declared consideration is not the actual consideration received.

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