Stamp valuation and unsupported FMV claims in capital gains may be rejected unless backed by reliable records and evidence.

Section 50C can be applied on the basis of stamp valuation where the conveyance record is incomplete, but any later alteration in the stamp-determined value may be addressed through the statutory revision mechanism under section 155(15). For cost of acquisition, the assessee must substantiate the claimed fair market value as on 01.04.1981 with credible evidence; a deficient valuer's report and unsupported assertions may be rejected in favour of the purchase price with appropriate appreciation. Salary additions based on a disputed certificate require verification against the return and corrected records before relief is granted.

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Issues: (i) whether the deemed sale consideration under section 50C could be applied on the basis of the stamp valuation when the higher value was stated to be under challenge and the record was incomplete; (ii) whether the cost of acquisition adopted by the Assessing Officer for the land was liable to be disturbed in favour of the assessee's claimed fair market value as on 01.04.1981; (iii) whether the salary addition was sustainable where the assessee claimed that the salary certificate filed before the Assessing Officer reflected a typographical mistake.

Issue (i): whether the deemed sale consideration under section 50C could be applied on the basis of the stamp valuation when the higher value was stated to be under challenge and the record was incomplete.

Analysis: The sale deed disclosed a lower declared consideration, while the Sub-Registrar's communication referred to a higher value and a notice under the Stamp Act. However, neither the appellate authorities nor the Tribunal had before them the complete conveyance deed, the final stamp valuation order, or proof of the status of any appeal. In this situation, the Tribunal noted that section 155(15) provides a statutory mechanism to revise the capital gains computation if the stamp-determined value is later altered in appeal, revision, or reference.

Conclusion: The issue was restored to the Assessing Officer for fresh verification and decision in accordance with law; the assessee obtained only statistical relief.

Issue (ii): whether the cost of acquisition adopted by the Assessing Officer for the land was liable to be disturbed in favour of the assessee's claimed fair market value as on 01.04.1981.

Analysis: The Tribunal held that the purchase deed of 17.04.1980 was the only reliable evidence of acquisition, and the recital about an earlier oral arrangement did not establish actual transfer in 1978. On the valuation question, the assessee bore the burden of substantiating the claimed fair market value by credible evidence. The registered valuer's report was found deficient because it described the property as residential but applied commercial rates without adequate supporting data or contemporaneous market evidence. The Assessing Officer's approach of taking the purchase price as a base and allowing appreciation was found more dependable.

Conclusion: The assessee's challenge to the cost of acquisition failed and the addition was sustained.

Issue (iii): whether the salary addition was sustainable where the assessee claimed that the salary certificate filed before the Assessing Officer reflected a typographical mistake.

Analysis: The assessee explained that the certificate filed during assessment corresponded to the subsequent financial year and not to the year under appeal, and a corrected certificate was produced before the appellate authority. The Tribunal directed verification of the salary certificates with the return of income and required the Assessing Officer to grant relief if the corrected figures were found to be in order.

Conclusion: The salary issue was remitted for verification and consequential relief, if eligible.

Final Conclusion: The appeal succeeded only in part, with one issue sent back for fresh examination, one issue rejected on merits, and the salary issue reopened for verification before the Assessing Officer.

Ratio Decidendi: Where the assessee's valuation evidence is unsupported or internally inconsistent, the authorities may reject it and rely on more reliable material for capital gains computation, while any later alteration in stamp valuation can be addressed through the statutory revision mechanism.

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