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    <title>1990 (4) TMI 99 - ITAT DELHI-C</title>
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    <description>Chapter XX-A acquisition could not be initiated without relevant primary material supporting a prima facie belief that the stated consideration was understated, and the section 269-C presumption could not be used to supply that missing foundation. The valuation also had to reflect the tenancy arrangement and the restrictions imposed by the Urban Land (Ceiling and Regulation) Act, 1976, because the property could not be treated as an unencumbered asset or valued on hypothetical redevelopment assumptions. Those legal burdens materially affected transferability, development potential, and market realisation, so the Revenue&#039;s valuation approach was unsustainable.</description>
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      <title>1990 (4) TMI 99 - ITAT DELHI-C</title>
      <link>https://www.taxtmi.com/caselaws?id=64006</link>
      <description>Chapter XX-A acquisition could not be initiated without relevant primary material supporting a prima facie belief that the stated consideration was understated, and the section 269-C presumption could not be used to supply that missing foundation. The valuation also had to reflect the tenancy arrangement and the restrictions imposed by the Urban Land (Ceiling and Regulation) Act, 1976, because the property could not be treated as an unencumbered asset or valued on hypothetical redevelopment assumptions. Those legal burdens materially affected transferability, development potential, and market realisation, so the Revenue&#039;s valuation approach was unsustainable.</description>
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