Estimation of on money: authorities may adjust consideration only when specific corroborated evidence shows undisclosed payments.
Revenue practice of extrapolating higher observed prices to estimate undeclared payments termed on money conflicts with the statutory role of stamp duty valuation as fair market value. Courts permit additions where specific, corroborated evidence or admissions establish receipt of extra payments for particular units, but have disallowed blanket estimation across other units lacking direct evidence, noting each sale is an independent contract with unit-specific value determinants. Absent cogent material, taxing notional income instead of real income is impermissible. (AI Summary)

Validity of search authorisation: appellate review may verify warrant existence but not re-evaluate the issuing officer's subjective satisfaction.
Challenge to a search under section 132 focuses on whether appellate review of an assessment under section 153A may encompass adjudication of the existence and legality of the warrant and the statutory conditions for issuance. Authorities converge that appellate bodies must verify existence of a warrant in the appellant's name, diverge on whether they may examine objectively the grounds for issuance, and uniformly regard assessment of the issuing officer's subjective satisfaction as generally non-justiciable. (AI Summary)