CIT v. Smt. Shakuntala\nDevi

316 ITR 46High Court2009#1550 most cited
73

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2010 to 2026.

Sections most often in play

Section 132Section 143(3)Section 132(4)Section 69Section 115BBESection 143(2)Section 153ASection 69C

Issues it is cited on

section 142asection 44afsection 132(5)section 131(1)(d)surrender of incomesection 150mat creditsection 55asection 100accumulated profitssection 158bdsection 38

Judgments citing CIT v. Smt. Shakuntala\nDevi

Shri Balram Krishan, Chandigarh vs. Deputy Commissioner of Income Tax, Central Circle-1, Chandigarh

ITA 728/CHANDI/2023[2014-15]Status: DisposedITAT Chandigarh03 Mar 2025AY 2014-15

Bench: Shri Sanjay Garg & Shri Krinwant Sahayआयकर अपील सं./Ita No. 579/Chd/2023 निर्धारण वर्ष / Assessment Year : 2017-18 & आयकर अपील सं./Ita Nos.582 To 584/Chd/2023 निर्धारण वर्ष / Assessment Years : 2014-15 To 2016-17 & आयकर अपील सं./Ita No. 591/Chd/2023 निर्धारण वर्ष / Assessment Year : 2018-19 Maxport India Pvt. Ltd. C/O Parikshit Aggarwal, Chartered Accountant, H. No. 3035, Sector 27D, Chandigarh- 160019. स्था.लेखा सं./Pan No: Aaicm9120E अपीलाथ/Appellant बनाम प्रथीय/Respondent Deputy Commissioner Of Income-Tax, Centre Circle-1, Chandigarh. & आयकर अपील सं./Ita Nos.482 & 483/Chd/2023 निर्धारण वर्ष / Assessment Years : 2017-18 & 2018-19 Vaishali Aggarwal C/O Parikshit Aggarwal, Chartered Accountant, H No. 3035, Sector 27D, Chandigarh- 160022. स्था.लेखा सं./Pan No: Aaqpa4025M अपीलाथ/Appellant बनाम प्रथीय/Respondent Deputy Commissioner Of Income-Tax, Centre Circle-1, Chandigarh. & आयकर अपील सं./Ita No. 846/Chd/2023

Section 127Section 132Section 153ASection 153DSection 2(22)(e)

…the case of CIT v. VinodSinghal (IT Appeal N o.482/2010 decided on 05.05.2010) where, again, reliance was placed on the very same decision of the Supreme Court in K.P. Varghese (supra) and also on a decision of this Court in CIT v. Smt. Shakuntala Devi [2009] 316 ITR 46. It was observed that there must be a finding that the assessee had received an amount over and above the consideration stated in the sale deed and for this the primary burden was cast on the revenue. It is only when this burden is discharged by the revenue that it would be permissible to rely upon the value as given in the valuation report of the…

Shri Balram Krishan, Chandigarh vs. Deputy Commissioner of Income Tax, Central Circle-1, Chandigarh

ITA 726/CHANDI/2023[2012-13]Status: DisposedITAT Chandigarh03 Mar 2025AY 2012-13
Section 153A

…the case of CIT v. VinodSinghal (IT Appeal No.482/2010 decided on 05.05.2010) where, again, reliance was placed on the very same decision of the Supreme Court in K.P. Varghese (supra) and also on a decision of this Court in CIT v. Smt. Shakuntala Devi [2009] 316 ITR 46. It was observed that there must be a finding that the assessee had received an amount over and above the consideration stated in the sale deed and for this the primary burden was cast on the revenue. It is only when this burden is discharged by the revenue that it would be permissible to rely upon the value as given in the valuation report of the…

Maxport India Private Limited, Chandigarh vs. Dy. Commissioner of Income Tax, Central Circle-1, Chandigarh

ITA 583/CHANDI/2023[2015-16]Status: DisposedITAT Chandigarh03 Mar 2025AY 2015-16
Section 127Section 132Section 153ASection 153DSection 2(22)(e)

…the case of CIT v. VinodSinghal (IT Appeal No.482/2010 decided on 05.05.2010) where, again, reliance was placed on the very same decision of the Supreme Court in K.P. Varghese (supra) and also on a decision of this Court in CIT v. Smt. Shakuntala Devi [2009] 316 ITR 46. It was observed that there must be a finding that the assessee had received an amount over and above the consideration stated in the sale deed and for this the primary burden was cast on the revenue. It is only when this burden is discharged by the revenue that it would be permissible to rely upon the value as given in the valuation report of the…

Maxport India Private Limited, Chandigarh vs. Dy. Commissioner of Income Tax, Central Circle-1, Chandigarh

ITA 582/CHANDI/2023[2014-15]Status: DisposedITAT Chandigarh03 Mar 2025AY 2014-15
Section 127Section 132Section 153ASection 153D

…the case of CIT v. VinodSinghal (IT Appeal No.482/2010 decided on 05.05.2010) where, again, reliance was placed on the very same decision of the Supreme Court in K.P. Varghese (supra) and also on a decision of this Court in CIT v. Smt. Shakuntala Devi [2009] 316 ITR 46. It was observed that there must be a finding that the assessee had received an amount over and above the consideration stated in the sale deed and for this the primary burden was cast on the revenue. It is only when this burden is discharged by the revenue that it would be permissible to rely upon the value as given in the valuation report of the…

DCIT, CC 1, Chandigarh vs. Sanjeev Aggarwal, Chandigarh

The appeals of the revenue are treated as dismissed

ITA 505/CHANDI/2023[2017-18]Status: DisposedITAT Chandigarh03 Mar 2025AY 2017-18
Section 127Section 153DSection 2

…the case of CIT v. VinodSinghal (IT Appeal No.482/2010 decided on 05.05.2010) where, again, reliance was placed on the very same decision of the Supreme Court in K.P. Varghese (supra) and also on a decision of this Court in CIT v. Smt. Shakuntala Devi [2009] 316 ITR 46. It was observed that there must be a finding that the assessee had received an amount over and above the consideration stated in the sale deed and for this the primary burden was cast on the revenue. It is only when this burden is discharged by the revenue that it would be permissible to rely upon the value as given in the valuation report of the…

Sanjeev Aggarwal, Chandigarh vs. Deputy Commissioner of Income Tax, Central Circle-1, Chandigarh

ITA 489/CHANDI/2023[2017-18]Status: DisposedITAT Chandigarh03 Mar 2025AY 2017-18
Section 127Section 132Section 153ASection 153D

…the case of CIT v. VinodSinghal (IT Appeal No.482/2010 decided on 05.05.2010) where, again, reliance was placed on the very same decision of the Supreme Court in K.P. Varghese (supra) and also on a decision of this Court in CIT v. Smt. Shakuntala Devi [2009] 316 ITR 46. It was observed that there must be a finding that the assessee had received an amount over and above the consideration stated in the sale deed and for this the primary burden was cast on the revenue. It is only when this burden is discharged by the revenue that it would be permissible to rely upon the value as given in the valuation report of the…

Sanjeev Aggarwal, Chandigarh vs. Deputy Commissioner of Income Tax, Central Circle-1, Chandigarh

ITA 480/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh03 Mar 2025AY 2018-19
Section 127Section 132Section 153ASection 153DSection 2(22)(e)

…the case of CIT v. VinodSinghal (IT Appeal No.482/2010 decided on 05.05.2010) where, again, reliance was placed on the very same decision of the Supreme Court in K.P. Varghese (supra) and also on a decision of this Court in CIT v. Smt. Shakuntala Devi [2009] 316 ITR 46. It was observed that there must be a finding that the assessee had received an amount over and above the consideration stated in the sale deed and for this the primary burden was cast on the revenue. It is only when this burden is discharged by the revenue that it would be permissible to rely upon the value as given in the valuation report of the…

DCIT, Jaipur vs. Amrapali Jewels Pvt. Ltd., Jaipur

In the result, the appeal filed by the assessee is partly allowed and

ITA 740/JPR/2024[2021]Status: DisposedITAT Jaipur19 Feb 2025

Bench: Him.

For Appellant: Sh. Sanjay Jhanwar, Sr. AdvFor Respondent: Mrs. Alka Gautam, CIT-DR
Section 143(3)Section 145(3)Section 153DSection 251Section 69B

…the case of CIT v. Vinod Singhal (IT Appeal No.482/2010 decided on 05.05.2010) where, again, reliance was placed on the very same decision of the Supreme Court in K.P. Varghese (supra) and also on a decision of this Court in CIT v. Smt. Shakuntala Devi [2009] 316 ITR 46. It was observed that there must be a finding that the assessee had received an amount over and above the consideration stated in the sale deed and for this the primary burden was cast on the revenue. It is only when this burden is discharged by the revenue that it would be permissible to rely upon the value as given in the valuation report of the…

Anil Chaudhary, New Delhi vs. ACIT Central Circle-17, New Delhi

In the result, appeals filed by the assessee are allowed

ITA 2938/DEL/2023[2017-18]Status: DisposedITAT Delhi30 Aug 2024AY 2017-18

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Gautam Jain, AdvocateFor Respondent: Ms. Amisha Gupt, CIT DR
Section 127Section 143(2)Section 153ASection 153CSection 153DSection 69C

…e assessment made by the ITO.” iv) 107 ITR 938 (SC) Roshan Di Hatt vs. CIT v) 328 ITR 513 (SC) Sargam Cinema vs. CIT vi) 131 ITR 597 (SC) K.P. Varghese vs. ITO vii) 261 ITR 664 (Del) CIT vs. Naresh Khattar (HUF) viii) 328 ITR 516 (Del) CIT vs. Naveen Gera ix) 316 ITR 46 (Del.) CIT vs. Shakuntala Devi x) 335 ITR 572 (Del.) CIT vs. Bajrang Lal Bansal xi) ITA no. 610/2012, Dated 19.10.2012 (Del) CIT vs Dinesh Jain HUF xii) ITA No. 176/204 dated 25.4.2014 (Del) CIT v. Agile Properties (P) Ltd. xiii) 81 taxmann.com 257 (Bom) CIT v. Devesh Agarwal, xiv) 64 taxmann.com 332 (Del) ACIT v.Rakesh Narang, xv) 22 SOT 174 (Mum…

Anil Chaudhary, New Delhi vs. ACIT Central Circle-17, New Delhi

In the result, appeals filed by the assessee are allowed

ITA 2937/DEL/2023[2016-17]Status: DisposedITAT Delhi30 Aug 2024AY 2016-17

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Gautam Jain, AdvocateFor Respondent: Ms. Amisha Gupt, CIT DR
Section 127Section 143(2)Section 153ASection 153CSection 153DSection 69C

…e assessment made by the ITO.” iv) 107 ITR 938 (SC) Roshan Di Hatt vs. CIT v) 328 ITR 513 (SC) Sargam Cinema vs. CIT vi) 131 ITR 597 (SC) K.P. Varghese vs. ITO vii) 261 ITR 664 (Del) CIT vs. Naresh Khattar (HUF) viii) 328 ITR 516 (Del) CIT vs. Naveen Gera ix) 316 ITR 46 (Del.) CIT vs. Shakuntala Devi x) 335 ITR 572 (Del.) CIT vs. Bajrang Lal Bansal xi) ITA no. 610/2012, Dated 19.10.2012 (Del) CIT vs Dinesh Jain HUF xii) ITA No. 176/204 dated 25.4.2014 (Del) CIT v. Agile Properties (P) Ltd. xiii) 81 taxmann.com 257 (Bom) CIT v. Devesh Agarwal, xiv) 64 taxmann.com 332 (Del) ACIT v.Rakesh Narang, xv) 22 SOT 174 (Mum…

Anil Chaudhary, New Delhi vs. ACIT Central Circle-17, New Delhi

In the result, appeals filed by the assessee are allowed

ITA 2936/DEL/2023[2015-16]Status: DisposedITAT Delhi30 Aug 2024AY 2015-16

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Gautam Jain, AdvocateFor Respondent: Ms. Amisha Gupt, CIT DR
Section 127Section 143(2)Section 153ASection 153CSection 153DSection 69C

…e assessment made by the ITO.” iv) 107 ITR 938 (SC) Roshan Di Hatt vs. CIT v) 328 ITR 513 (SC) Sargam Cinema vs. CIT vi) 131 ITR 597 (SC) K.P. Varghese vs. ITO vii) 261 ITR 664 (Del) CIT vs. Naresh Khattar (HUF) viii) 328 ITR 516 (Del) CIT vs. Naveen Gera ix) 316 ITR 46 (Del.) CIT vs. Shakuntala Devi x) 335 ITR 572 (Del.) CIT vs. Bajrang Lal Bansal xi) ITA no. 610/2012, Dated 19.10.2012 (Del) CIT vs Dinesh Jain HUF xii) ITA No. 176/204 dated 25.4.2014 (Del) CIT v. Agile Properties (P) Ltd. xiii) 81 taxmann.com 257 (Bom) CIT v. Devesh Agarwal, xiv) 64 taxmann.com 332 (Del) ACIT v.Rakesh Narang, xv) 22 SOT 174 (Mum…

Anil Chaudhary, New Delhi vs. ACIT Central Circle-17, New Delhi

In the result, appeals filed by the assessee are allowed

ITA 2935/DEL/2023[2014-15]Status: DisposedITAT Delhi30 Aug 2024AY 2014-15

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Gautam Jain, AdvocateFor Respondent: Ms. Amisha Gupt, CIT DR
Section 127Section 143(2)Section 153ASection 153CSection 153DSection 69C

…e assessment made by the ITO.” iv) 107 ITR 938 (SC) Roshan Di Hatt vs. CIT v) 328 ITR 513 (SC) Sargam Cinema vs. CIT vi) 131 ITR 597 (SC) K.P. Varghese vs. ITO vii) 261 ITR 664 (Del) CIT vs. Naresh Khattar (HUF) viii) 328 ITR 516 (Del) CIT vs. Naveen Gera ix) 316 ITR 46 (Del.) CIT vs. Shakuntala Devi x) 335 ITR 572 (Del.) CIT vs. Bajrang Lal Bansal xi) ITA no. 610/2012, Dated 19.10.2012 (Del) CIT vs Dinesh Jain HUF xii) ITA No. 176/204 dated 25.4.2014 (Del) CIT v. Agile Properties (P) Ltd. xiii) 81 taxmann.com 257 (Bom) CIT v. Devesh Agarwal, xiv) 64 taxmann.com 332 (Del) ACIT v.Rakesh Narang, xv) 22 SOT 174 (Mum…

Khanna Infrabuild Private Limited 2000-1A, Sukhdev Nagar Ferozepur Road, Ludhiana vs. The Deputy Commissioner of Income Tax Central Circle-2 Ludhiana, Ludhiana

In the result, the ground of appeal is allowed

ITA 679/CHANDI/2023[2019-2020]Status: DisposedITAT Chandigarh28 Jun 2024AY 2019-2020

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Rohit Sharma, CIT, DR
Section 115BSection 145(3)Section 153ASection 35ASection 69

…the case of CIT v. VinodSinghal (IT Appeal No.482/2010 decided on 05.05.2010) where, again, reliance was placed on the very same decision of the Supreme Court in K.P. Varghese (supra) and also on a decision of this Court in CIT v. Smt. Shakuntala Devi [2009] 316 ITR 46. It was observed that there must be a finding that the assessee had received an amount over and above the consideration stated in the sale deed and for this the primary burden was cast on the revenue. It is only when this burden is discharged by the revenue that it would be permissible to rely upon the value as given in the valuation report of the…

Khanna Infrabuild Private Limited, Ludhiana vs. The Deputy Commissioner of Income Tax (Central Circle)-2, Ludhiana

In the result, the ground of appeal is allowed

ITA 668/CHANDI/2023[2018-2019]Status: DisposedITAT Chandigarh28 Jun 2024AY 2018-2019

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Rohit Sharma, CIT, DR
Section 115BSection 145(3)Section 153ASection 35ASection 69

…the case of CIT v. VinodSinghal (IT Appeal No.482/2010 decided on 05.05.2010) where, again, reliance was placed on the very same decision of the Supreme Court in K.P. Varghese (supra) and also on a decision of this Court in CIT v. Smt. Shakuntala Devi [2009] 316 ITR 46. It was observed that there must be a finding that the assessee had received an amount over and above the consideration stated in the sale deed and for this the primary burden was cast on the revenue. It is only when this burden is discharged by the revenue that it would be permissible to rely upon the value as given in the valuation report of the…

Khanna Infrabuild Private Limited, Ludhiana vs. The Deputy Commissioner of Income Tax (Central Circle)-2 Ludhiana, Ludhiana

In the result, the ground of appeal is allowed

ITA 663/CHANDI/2023[2017-2018]Status: DisposedITAT Chandigarh28 Jun 2024AY 2017-2018

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Rohit Sharma, CIT, DR
Section 115BSection 145(3)Section 153ASection 35ASection 69

…the case of CIT v. VinodSinghal (IT Appeal No.482/2010 decided on 05.05.2010) where, again, reliance was placed on the very same decision of the Supreme Court in K.P. Varghese (supra) and also on a decision of this Court in CIT v. Smt. Shakuntala Devi [2009] 316 ITR 46. It was observed that there must be a finding that the assessee had received an amount over and above the consideration stated in the sale deed and for this the primary burden was cast on the revenue. It is only when this burden is discharged by the revenue that it would be permissible to rely upon the value as given in the valuation report of the…

Jayanta Kumar Sardar, Bardhaman vs. ITO, Ward-2(4), Durgapur.

In the result, the appeal filed by the assessee in ITA No

ITA 1251/KOL/2023[2016-17]Status: DisposedITAT Kolkata30 Jan 2024AY 2016-17

Bench: Dr. Manish Borad & Sri Anikesh Banerjee

Section 139(1)Section 143(3)Section 250Section 56(2)(viib)

…r has to apply his mind to the information, if any, collected and must form a belief thereon. In the circumstances, there is no merit in the civil appeal. The Department was not entitled to reopen the assessment." In the case of CIT vs. Shakuntala Devi [2009] 316 ITR 46, (DEL) held as under: - "It may be relevant to note that a Division Bench of this court, comprising Dr. Arijit Pasayat and D. K. Jain JJ., as their Lordships then were, reiterated that there must be a finding of the Revenue that the assessee had received amounts over and above the consideration stated in the sale deeds, following Varghese [1981 ]…

Jaswinder Kaur Anand, Delhi vs. ACIT Central Circle-1, Delhi

In the result, the appeal of the revenue on this ground is dismissed

ITA 1146/DEL/2021[2018-19]Status: DisposedITAT Delhi16 Oct 2023AY 2018-19

Bench: Sh. C. M. Gargdr. B. R. R. Kumar

For Appellant: Sh. Salil Kapoor, Adv. &For Respondent: Mr. Waseem Arshad, CIT-DR
Section 132Section 133ASection 269SSection 69B

…s in the valuation report is exactly similar as what has been purchased by the assessee. The ld. CIT(A) relied on the judgments in the case of,  Gautam Laljibhai Gajjar Vs. ITO (37 ITD 514)  Dinesh Jain Vs. DCIT (34 SOT 444)  CIT Vs. Smt. Shakuntala Devi (316 ITR 46) (Del.)  K.P. Varghese Vs. ITO (131 ITR 597) (SC) 34. Having gone through the facts of the case narrated above and judgments relied upon by the ld. CIT(A), we are in total agreement with the decision of the ld. CIT(A) in deleting the addition. ITA Nos. 1145 & 1146/Del/2021 14 Jasmine Anand & Jaswinder Kaur Anand 35. In the result, the appeal…

Jasmine Anand, Delhi vs. ACIT, Central Circle-1, Delhi

In the result, the appeal of the revenue on this ground is dismissed

ITA 1145/DEL/2021[2018-19]Status: DisposedITAT Delhi16 Oct 2023AY 2018-19

Bench: Sh. C. M. Gargdr. B. R. R. Kumar

For Appellant: Sh. Salil Kapoor, Adv. &For Respondent: Mr. Waseem Arshad, CIT-DR
Section 132Section 133ASection 269SSection 69B

…s in the valuation report is exactly similar as what has been purchased by the assessee. The ld. CIT(A) relied on the judgments in the case of,  Gautam Laljibhai Gajjar Vs. ITO (37 ITD 514)  Dinesh Jain Vs. DCIT (34 SOT 444)  CIT Vs. Smt. Shakuntala Devi (316 ITR 46) (Del.)  K.P. Varghese Vs. ITO (131 ITR 597) (SC) 34. Having gone through the facts of the case narrated above and judgments relied upon by the ld. CIT(A), we are in total agreement with the decision of the ld. CIT(A) in deleting the addition. ITA Nos. 1145 & 1146/Del/2021 14 Jasmine Anand & Jaswinder Kaur Anand 35. In the result, the appeal…

Assistant Commissioner of Income Tax, Central Circle -I, Raipur vs. Lord Buddha Educational Society, Raipur

In the result, the appeals of the revenue ITA Nos

ITA 193/RPR/2019[2017-18]Status: DisposedITAT Raipur27 Mar 2023AY 2017-18

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अऩीऱ सं./Ita Nos.188 To 193/Rpr/2019 (ननधाारण वषा / Assessment Year :2012-2013 To 2017-2018) Acit, Central Circle-1, Raipur(Cg) Vs M/S Lord Buddha Educational Society, M/S Raipur Institute Of Medical Sciences (Rims), Gram Godhi, Bhansoj Road, Office Nh-6, Raipur (Cg) Pan No. :Aaaal 3913 E (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

For Appellant: Shri R.B.Doshi, CAFor Respondent: Shri Debashish Lahiri, CIT-DR
Section 12ASection 143(3)

…the case of CIT v. Vinod Singhal (IT Appeal No.482/2010 decided on 05.05.2010) where, again, reliance was placed on the very same decision of the Supreme Court in K.P. Varghese (supra) and also on a decision of this Court in CIT v. Smt. Shakuntala Devi [2009] 316 ITR 46. It was observed that there must be a finding that the assessee had received an amount over and above the consideration stated in the sale deed and for this the primary burden was cast on the revenue. It is only when this burden is discharged by the revenue that it would be permissible to rely upon the value as given in the valuation report of the…

Assistant Commissioner of Income Tax, Central Circle -I, Raipur vs. Lord Buddha Educational Society, Raipur

In the result, the appeals of the revenue ITA Nos

ITA 192/RPR/2019[2016-17]Status: DisposedITAT Raipur27 Mar 2023AY 2016-17

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अऩीऱ सं./Ita Nos.188 To 193/Rpr/2019 (ननधाारण वषा / Assessment Year :2012-2013 To 2017-2018) Acit, Central Circle-1, Raipur(Cg) Vs M/S Lord Buddha Educational Society, M/S Raipur Institute Of Medical Sciences (Rims), Gram Godhi, Bhansoj Road, Office Nh-6, Raipur (Cg) Pan No. :Aaaal 3913 E (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

For Appellant: Shri R.B.Doshi, CAFor Respondent: Shri Debashish Lahiri, CIT-DR
Section 12ASection 143(3)

…the case of CIT v. Vinod Singhal (IT Appeal No.482/2010 decided on 05.05.2010) where, again, reliance was placed on the very same decision of the Supreme Court in K.P. Varghese (supra) and also on a decision of this Court in CIT v. Smt. Shakuntala Devi [2009] 316 ITR 46. It was observed that there must be a finding that the assessee had received an amount over and above the consideration stated in the sale deed and for this the primary burden was cast on the revenue. It is only when this burden is discharged by the revenue that it would be permissible to rely upon the value as given in the valuation report of the…