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Taxpayer's Capital Gains Revised: Section 263 and 50C Support Reassessment of 23-Acre Land Sale for Unverified Cost Basis.

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....Revision u/s 263 - capital gains computation on the sale by the assessee of 23 acres of his land - the cost adopted by him was neither enquired into in assessment nor, consequently, substantiated - This is even as the stamp valuation itself is guided by the consideration of fmv of the relevant property, making the provision complete and legally firm. It is for this reason that we stated the argument advanced by and on assessee’s behalf to be flawed, both in law and on facts. To conclude, s.50C is clearly applicable, and which forms another reason for upholding the revision. - AT....