Section 50C applies to land transfers for consideration when the dispute is factual, not a substantial question of law.

Section 50C of the Income-tax Act was treated as applicable where a registered sale deed showed consideration below stamp value for transfer of land or building for consideration. The Court found no material showing that RIICO had exclusive possession or that only a limited right, rather than the land itself, had been transferred. It held that the dispute turned on factual characterisation of the transaction, not on any settled legal error, and therefore no substantial question of law arose. The stamp-value based addition was left undisturbed and no relief followed in appeal.

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Issues: (i) Whether section 50C of the Income-tax Act, 1961 applied to the registered sale deed executed by the assessee, and whether the dispute raised any substantial question of law warranting interference.

Analysis: The consideration recorded in the sale deed was lower than the stamp value adopted by the registering authority. The Court found that the transaction was a transfer of capital asset for consideration and that the record did not establish exclusive possession of RIICO so as to show that only a limited right, and not the land itself, had been transferred. The Court further held that section 50C is a deeming provision applicable where a capital asset being land or building, or both, is transferred for consideration, and that the dispute turned on appreciation of facts rather than on any settled legal error. On that basis, no substantial question of law arose.

Conclusion: Section 50C was held applicable on the facts, and the appeal was not entertained for want of a substantial question of law.

Final Conclusion: The addition based on stamp valuation was left undisturbed and the assessee obtained no relief in appeal.

Ratio Decidendi: Section 50C applies to a transfer of a capital asset being land or building, or both, for consideration, and a dispute centered on factual characterisation of the transfer does not, by itself, give rise to a substantial question of law.

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