Stamp duty valuation objections require Valuation Officer reference before determining taxable property-value differences under Section 56(2)(x).

Where a taxpayer specifically objects to stamp duty valuation for purposes of Section 56(2)(x), the fair market value must be determined through a reference to the Valuation Officer before that valuation is adopted. Property-specific factors affecting market value and an unaddressed request for such reference make direct adoption of stamp duty values inappropriate. Valuation reports concerning the disputed fair market values may be admitted as additional evidence where they are material to determining the addition. The valuation matter was restored for fresh determination after providing the taxpayer a reasonable opportunity.

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Issues: Whether stamp duty valuation could be adopted for taxing the difference between purchase consideration and such valuation under Section 56(2)(x) without referring the assessee's objection to the Valuation Officer; and whether valuation reports produced in appeal should be admitted as additional evidence.

Issue (i): Whether stamp duty valuation could be adopted for taxing the difference between purchase consideration and such valuation under Section 56(2)(x) without referring the assessee's objection to the Valuation Officer.

Analysis: The assessee had specifically disputed the stamp duty values by identifying property-specific factors affecting market value and requested a valuation reference. No reason was recorded for declining that request. Where the assessee objects to adoption of stamp duty valuation, such valuation cannot be adopted for invoking Section 56(2)(x) without a reference to the Valuation Officer.

Conclusion: The issue was decided in favour of the assessee; the fair market value must be determined through a reference to the Valuation Officer.

Issue (ii): Whether valuation reports for the three properties should be admitted as additional evidence.

Analysis: The valuation reports directly concerned the disputed fair market values and were material to determination of the addition.

Conclusion: The issue was decided in favour of the assessee; the valuation reports were admitted as additional evidence.

Final Conclusion: The valuation issue was restored for fresh determination of the properties' fair market value after providing the assessee a reasonable opportunity.

Ratio Decidendi: Upon a specific objection to stamp duty valuation for purposes of Section 56(2)(x), fair market value must be determined by reference to the Valuation Officer before that valuation is adopted.

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