Section 50C applies to registered land transfers where factual possession claims do not displace the deed, leaving no substantial question of law.

A registered sale deed for land executed for consideration attracted section 50C because the record did not show that the land had ceased to be a capital asset or that possession had passed in a way that displaced the registered transfer. The dispute turned mainly on factual assertions about possession and the character of the rights transferred, and no demonstrable legal error by the Tribunal was shown. Section 50C therefore applied, no substantial question of law arose, and the assessee's challenge to the addition failed.

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Issues: (i) Whether the transfer of the land attracted section 50C of the Income-tax Act, 1961, and whether the appeal raised any substantial question of law.

Analysis: The sale deed was executed for consideration and was registered, while the stamp valuation adopted by the registering authority was much higher. The record did not establish that the land had ceased to be a capital asset or that possession had vested in RIICO in a manner displacing the effect of the registered sale transaction. The challenge turned essentially on the factual character of the transfer and the applicability of the deeming provision under section 50C. On the material available, the Court found no basis to hold that the Tribunal had committed any legal error warranting interference.

Conclusion: Section 50C applied to the transfer in question, and no substantial question of law arose. The appeal failed.

Final Conclusion: The assessee's challenge to the addition made by invoking section 50C was rejected, and the dismissal of the appeal was upheld.

Ratio Decidendi: Where a registered sale deed of land is executed for consideration and the dispute is only about factual assertions regarding possession or the character of the rights transferred, section 50C can apply and no substantial question of law arises absent a demonstrable legal error.

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