Section 50C valuation must follow the final stamp revision result when objection is raised during assessment.

Where an assessee objects to the stamp valuation during assessment under section 50C and a revision against that valuation is later pending, the valuation issue should be aligned with the final outcome of the revision proceedings before capital gains are computed. The initial objection before the Assessing Officer satisfied the statutory requirement for reference, and the later revision meant the stamp valuation could not be treated as settled. The proper course was to restore the matter for fresh consideration after the revision result, with reasonable opportunity to the assessee.

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Issues: Whether, on the assessee objecting to the stamp duty valuation during assessment and later filing a revision against the stamp valuation order, the matter was required to be referred to the Valuation Officer under section 50C(2) and the valuation issue reconsidered in light of the subsequent revision proceedings.

Analysis: The assessee had challenged the enhanced stamp valuation before the Assessing Officer during assessment proceedings, satisfying the first requirement under section 50C(2). The subsequent revision before the Tax Board was filed after the assessment order, so the Assessing Officer could not have acted on that later development at the time of assessment. However, once the appellate authority was informed of the revision, the valuation adopted by the stamp authority became subject to the outcome of those proceedings. In these circumstances, the proper course was to restore the matter so that the final stamp valuation result could be taken into account before computing capital gains.

Conclusion: The valuation issue was remanded to the Assessing Officer for reconsideration after taking into account the outcome of the revision proceedings, with reasonable opportunity to the assessee.

Ratio Decidendi: Where an assessee objects to stamp valuation before the Assessing Officer and the challenge to that valuation is pending in revision, the valuation for section 50C purposes must be determined with reference to the final result of the revision proceedings, and the matter may be restored for fresh consideration.

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