Stamp duty valuation alone cannot prove extra sale consideration for a deemed gift when no higher payment is evidenced.

Stamp duty valuation cannot, by itself, be treated as the actual sale consideration for computing a deemed gift under the Gift-tax Act where the sale deed records a stated price and there is no evidence of any higher consideration having been received. In the absence of material proving extra consideration, a differential based only on the Sub-Registrar's stamp duty value does not support an addition as a deemed gift. The deletion of the addition was therefore upheld.

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Issues: Whether the value adopted by the Sub-Registrar for stamp duty purposes could be treated as the actual sale consideration for computing a deemed gift under section 4(1)(a) of the Gift-tax Act, 1958.

Analysis: The sale deed disclosed a stated consideration, and there was no material on record to show that any higher consideration had in fact been received. The valuation adopted for stamp duty could not, by itself, be treated as the real sale consideration. In the absence of evidence proving extra consideration, the differential based only on stamp duty valuation could not sustain an addition as a deemed gift.

Conclusion: The addition made on the footing of a deemed gift was rightly deleted.

Ratio Decidendi: Stamp duty valuation, without supporting evidence of actual extra consideration, cannot be used to compute a deemed gift.

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