Stamp duty valuation cannot by itself prove extra sale consideration or unexplained property investment without supporting evidence.

Stamp duty valuation alone could not establish higher sale consideration or unexplained investment in property; the disclosed consideration was accepted after inquiry and verification of bank records. Section 50C was treated as a deeming provision limited to capital gains computation and not as proof of extra money passing between parties. In the absence of positive evidence of additional consideration, the Tribunal's deletion of the addition was found free from legal infirmity, and no substantial question of law arose.

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Issues: Whether the Revenue's appeal raised any substantial question of law arising from the Tribunal's affirmation of the deletion of addition based on stamp duty valuation and alleged unexplained investment in property.

Analysis: The sale consideration disclosed in the sale deed was accepted after inquiry, including verification of bank statements and comments obtained by the first appellate authority from the Assessing Officer. The valuation adopted for stamp duty purposes could not, by itself, be treated as proof of higher consideration or unexplained investment. Section 50C operates as a deeming provision for computation of capital gains and does not dispense with the need for supporting evidence where the allegation is that more money passed between the parties. In the absence of positive evidence of extra consideration, and in view of the accepted factual findings, no legal infirmity was shown in the Tribunal's order. The view taken was also supported by consistency with the judicial approach relied upon below.

Conclusion: The addition was not sustainable, and no substantial question of law arose for consideration.

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