Section 50C valuation follows the registered agreement date when possession and part payment precede the sale deed.

For capital gains computation under section 50C, where a registered agreement to sell had already transferred possession and part consideration was received through banking channels, the relevant stamp valuation was the one in force on the agreement date. The later sale deed and any enhanced valuation linked to that date could not override the earlier registered agreement valuation. The proviso to section 50C, addressing cases where agreement and registration dates differ and consideration is not paid in cash, supported adoption of the agreement-date stamp value.

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Issues: Whether, for computing capital gains under section 50C, the full value of consideration was to be taken with reference to the stamp valuation on the date of the registered sale agreement with possession and part payment, or on the date of the subsequent sale deed.

Analysis: The agreement to sell was registered, possession was handed over, and part consideration was received through banking channels before execution of the sale deed. On these facts, the transaction had effectively commenced on the agreement date, and the stamp valuation available on that date was the relevant figure for section 50C purposes. The later enhancement by the District Registrar was tied to the sale deed date and could not displace the valuation already adopted at the stage of the registered agreement. The proviso to section 50C, inserted to address cases where the agreement date and registration date differ and consideration is received otherwise than in cash, supports adoption of the agreement-date valuation.

Conclusion: The full value of consideration had to be determined with reference to the stamp valuation as on the date of the registered sale agreement, and not the enhanced valuation adopted on the date of the sale deed.

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