Section 50C valuation must follow the taxpayer's statutory objection rights; summary adjustment under rectification was unsustainable.

Section 50C must be applied as a complete deeming mechanism, including the taxpayer's right under section 50C(2) to object to the stamp duty value and seek a valuation reference. A capital gains adjustment based on section 50C cannot be made summarily in processing and then justified under section 154, because denying the assessee that statutory opportunity goes beyond correction of a mere apparent error. The addition made by the CPC was therefore unsustainable, and deletion of the adjustment was justified in favour of the assessee.

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Issues: Whether the CPC could make an addition towards long-term capital gain under section 154 by applying section 50C, without giving the assessee the opportunity contemplated under section 50C(2).

Analysis: The adjustment was made in the course of processing and was sought to be sustained through section 154. The Tribunal held that section 50C is a deeming provision that must be read as a whole, including the mechanism under section 50C(2) enabling the assessee to object to the stamp duty value and seek valuation reference. Such a substantive adjustment cannot be made in a summary manner so as to deprive the assessee of that statutory right, and it is not an error that can validly be corrected under section 154.

Conclusion: The addition made by the CPC and sustained in appeal was unsustainable, and the deletion of the addition was justified in favour of the assessee.

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