“stamp duty value”

Capital GainsSection 50CSection 50C1,254 judgments

The decision most relied on for stamp duty value is Sunil Kumar Agarwal v. CIT (372 ITR 83), cited in 159 judgments on BharatTax.

Leading authorities on stamp duty value

Sunil Kumar Agarwal v. CIT

372 ITR 83 · 2015 · High Court

159

citing judgments

The Assessing Officer is duty-bound to refer the valuation of property to the Departmental Valuation Officer under Section 50C(2) when an assessee disputes the stamp duty valuation or if there is a discrepancy between the actual sale consideration and the guideline value. This reference is mandatory, even if not explicitly requested by the assessee, to ensure a realistic fair market value and avoid injustice.

Maria Fernandes Cheryl v. ITO (International Taxation)

123 Taxmann.com 252 · 2021 · ITAT

citing judgments

The amendment introducing a tolerance band (safe harbour) under section 50C, allowing a difference of up to 10% between actual sale consideration and stamp duty valuation, applies retrospectively. If the difference falls within this limit, the actual sale consideration is adopted as the full value of consideration for computing capital gains.

Maria Fernandes Cheryl v. ITO

187 ITD 738 · 2021 · ITAT

citing judgments

The third proviso to Section 50C(1) of the Income-tax Act, 1961, which provides a tolerance band of 10% between the sale consideration and the stamp duty value, is retrospective. This curative and declaratory amendment applies from the date of the insertion of Section 50C.

PCIT v. Swananda Properties (P.) Ltd.

111 Taxmann.com 94 · 2019 · High Court

citing judgments

Prior to the incorporation of the proviso to section 43CA(1) with effect from 1st April 2019, section 43CA did not envisage any limit regarding the difference between the stamp duty value and the actual sale consideration received by the assessee for the transfer of immovable property that was stock-in-trade.

Dharmashibhai Sonani v. ACIT

161 ITD 627 · 2016 · ITAT

citing judgments

Dharmashibhai Sonani holds that if a statutory proviso is declaratory and curative, intended to remedy unintended consequences of a main provision, it should be given retrospective effect. This principle applies when determining the effective date of such provisos, including the third proviso to Section 50C(1).

Atul G. Puranik v. ITO

132 ITD 499 · 2011 · ITAT

citing judgments

Section 50C of the Income Tax Act, 1961, which is a deeming provision, applies only to the transfer of "land or building or both" and therefore does not apply to the transfer of leasehold rights.

CIT v. Vummudi Amarendran

429 ITR 97 · 2020 · High Court

citing judgments

The first and second provisos to Section 50C(1) are retrospective in nature and applicable from the inception of the main section. The third proviso to Section 50C(1) is also retrospective and applies from the same date as the main provision.

P Varghese v. ITO

24 CTR 358 · 1981 · Supreme Court

citing judgments

The Revenue must prove that the assessee received more consideration than declared when challenging a sale transaction. The declared sale consideration is accepted unless evidence proves otherwise.

Judgments citing stamp duty value

Gopal Kundu Roy, Siliguri vs. ITO, Ward 1(3), Siliguri

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 2263/KOL/2025[2014-2015]Status: DisposedITAT Kolkata09 Dec 2025AY 2014-2015

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 2263/Kol/2025 Assessment Year: 2014-2015 Gopal Kundu Roy,……………………………….…Appellant ‘Hare Krishna Bhawan’, P.O. Rabindra Sarani, Rathkhola Bazar, Siliguri-734006, West Bengal [Pan:Acgpr0359H] -Vs.- Income Tax Officer,……………………………..Respondent Ward-1(3), Siliguri, Aayakar Bhawan, Paribahan Nagar, Matigara, Dist. Darjeeling-734010, W.B.

Section 139(1)Section 143(1)Section 147Section 148Section 271(1)(c)Section 54F

individual. During the year under appeal, the assessee had sold his landed property for Rs.15,00,000/- on 03.09.2013 and the stamp duty value of the same was for Rs.15,09,374/-. The assessee had invested the sale proceeds of Rs.15,00,000/- in construction of his new house property ... Assessing Officer observed that the assessee had sold his landed property for Rs.3,00,000/- and not for Rs.15,00,000/-, the stamp duty value of which was for Rs.15,09,374/- and observed that the assessee did not file his return of income and reopened the assessment under section

Asirvad Micro Finance Limited, Anna Salai vs. Assistant Commissioner of Income Tax, Corporate Circle -1(1), Chennai

In the result, the appeal of the assessee is allowed

ITA 1140/CHNY/2025[2016-17]Status: DisposedITAT Chennai05 Dec 2025AY 2016-17

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1140/Chny/2025 Assessment Years: 2016-17 Asirvad Micro Finance Limited, Assistant Commissioner Of No.9, 9Th Floor, Club House Road, Income Tax, Annasalai, Corporate Circle-1(1), Chennai-600 002 Chennai. [Pan: Aagca5275J] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Mr.P.R.Prasanna Varma, Fca & Mr.Arjun Rajagopalan, C.A. प्रत्यर्थी की ओर से /Revenue By : Mr.Bipin C.N, Cit सुनवाई की तारीख/Date Of Hearing : 25.09.2025 घोषणा की तारीख /Date Of Pronouncement : 05.12.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

For Appellant: Mr.P.R.Prasanna Varma, FCA &For Respondent: Mr.Bipin C.N, CIT

Section 2(18)Section 2(71)Section 56(2)Section 56(2)(viib)Section 8

which exceeds fifty thousand rupees, the whole of the aggregate value of such sum;(b)any immovable property,—(i)without consideration, the stamp duty value of which exceeds fifty thousand rupees, the stamp duty value of such property;(ii)for a consideration which is less than the stamp duty value ... property by an amount exceeding fifty thousand rupees, Page - 10 - of 16 the stamp duty value of such property as exceeds such consideration:Provided that where the date of the agreement fixing the amount of consideration for the transfer of immovable property and the date of registration

Baldev Singh Bhadoriya, Gwalior vs. ITO-3(2), Gwalior

In the result, the appeal of the Assessee is allowed for statistical purposes

ITA 37/AGR/2023[2015-16]Status: DisposedITAT Agra04 Dec 2025AY 2015-16

Bench: Shri M. Balaganesh & Shri Sunil Kumar Singh(Through Virtual Hearing) Smt Kiran Lata Bhadoria, Vs. Income Tax Officer, Ward- L/H Of Late Shri Baldev 3(2), Singh Bhadoria, Gwalior Mig-20, Darpan Colony, 474005, Mp (Appellant) (Respondent) Pan: Ahopb3071D Assessee By : Shri Somil Agarwal, Adv Shri Deepesh Garg, Adv Revenue By: Shri Sukesh Kumar Jain, Cit(Dr) Date Of Hearing 15/09/2025 Date Of Pronouncement 04/12/2025

For Appellant: Shri Somil Agarwal, AdvFor Respondent: Shri Sukesh Kumar Jain, CIT(DR)

Section 143(3)Section 56(2)(vii)

facts and circumstances of the instant case ? b) Whether an addition of Rs. 5,24,34,000/- could be made by adopting the stamp duty value as purchase consideration under Section 56(2)(vii) of the Act, in the facts and circumstances of the instant case for purchase of agricultural ... dated 7-02-2025 of a Registered Valuer which showed that the fair market value of the said land was lower than the stamp duty value. This is enclosed in pages 168 to 172 of the paper book. e) Copy of No Objection Certificate (NOC) taken by the seller from

Bipin Dharamshi Savla, Mumbai vs. ITO Ward -22(1)(1), Mumbai

In the result, appeal of the assessee is allowed for

ITA 6288/MUM/2025[2018-19]Status: DisposedITAT Mumbai03 Dec 2025AY 2018-19

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

Section 143Section 50CSection 54

Officer received information from the Sub-Registrar, Mumbai City that the Assessee had sold the immovable property for Rs.89,80,000/-, but the stamp duty value of the same was adopted at Rs.96,14,500/- by the Sub- Registrar for the purpose of stamp duty valuation. On verification from return ... Assessing Officer accepted the contention of the Assessee and took balance amount of Rs. 72,34,500/- for the purpose of the stamp duty value of flat as against sale consideration of Rs.66,00,000/- shown by the Assessee in the return of income and therefore, he made addition

Zulekha Haji Attarwala, Mumbai vs. ITO 20(2)(1), Lalbaug

In the result, the grounds of appeal and the appeal filed by the

ITA 4978/MUM/2025[2018-19]Status: DisposedITAT Mumbai03 Dec 2025AY 2018-19

Bench: Justice (Retd.) C. V. Bhadang & Shri Prabhash Shankar

For Appellant: Shri Bhupendra Shah, ARFor Respondent: Shri Swapnil Choudhary, (Sr. DR)

Section 143(3)Section 2(14)Section 234Section 270ASection 54Section 56(2)(x)

Purchase Consideration for Flat No. 4902, Orchid Enclave 'B' Wing, Bellasis Road, Mumbai Central (East)-400008, amounting to Rs.1,78,87,500/-and Stamp Duty Value of the said flat amounting to Rs.2,20,38,408/- as on 15th May, 2015, viz, the date when the Appellant had made first ... Rs.48,56,250/- towards purchase of immovable property. As per the first proviso to section 56(2)(x)(b) of the Act, Stamp duty value was required to be taken into consideration. The stamp duty value i.e. Market Value of the property in question was Rs.2

Mr. Akil Abbas Rassai, Mumbai vs. The Deputy Commissioner of Income Tax, Circle 22(1), Mumbai

The appeal of the assessee is allowed for statistical purposes

ITA 5761/MUM/2025[2018-19]Status: DisposedITAT Mumbai02 Dec 2025AY 2018-19

Bench: Shri Saktijit Dey, Vp & Ms Padmavathy S, Am

For Appellant: Shri Rakesh Joshi, AR

Section 142(1)Section 143(2)Section 143(3)Section 144BSection 250Section 56(2)(x)

making an addition of Rs.82,35,500/-u/s.56(2)(x) of the Income Tax Act, 1961 being difference between purchase consideration and stamp duty value of the property, without considering the facts and circumstances of the case. 3. On the facts and circumstances of the case as well ... assessee. The Assessing Officer (AO) notice that the assessee has purchased immovable property for a consideration which is lower than the stamp duty value. The AO accordingly issued a notice u/s. 142(1) calling for the assessee to submit the details pertaining to the impugned transaction and to explain

Alpesh Chandulal Modi, Mumbai vs. ITO Ward 16 (2) (1), Mumbai

Appeal of the assessee is allowed

ITA 5748/MUM/2025[2012-13]Status: DisposedITAT Mumbai02 Dec 2025AY 2012-13

Bench: Shri Saktijit Dey, Vp & Ms Padmavathy S, Am

For Respondent: Shri Surendra Mohan, Sr. DR

Section 133ASection 143(3)Section 148Section 151Section 250Section 292C

which warrants the addition made by the AO. We further notice that the sale consideration paid by the assessee is more than the stamp duty value of the flat and if the alleged cash payment is considered to be part of sale consideration then there is no logic that ... assessee would have paid double the stamp duty value towards purchase more so without any material evidence to the contrary. We also notice that the Co-ordinate bench while considering an identical addition made in the case of Jitesh Jitendra Sakidas (supra) based on the same survey has held that

Laxman Kanaiyalal Dharmani, Mumbai vs. Income Tax Officer Ward 23(2)(6), Mumbai

The appeal of the assessee is allowed

ITA 5675/MUM/2025[2018-19]Status: DisposedITAT Mumbai02 Dec 2025AY 2018-19

Bench: Shri Saktijit Dey, Vp & Ms Padmavathy S, Am

For Appellant: Shri Gunjan Kakkad, AR

Section 250Section 56(2)(x)

entered into a formal agreement with the assessee on 31.03.2017 registering the additional area of 159 sq.ft. in favour of the assessee. The stamp duty value of the entire flat was at Rs. 84,55,500/-. 3. The Assessing Officer (AO) after perusing the above facts and the purchase document ... submitted by the assessee issued a show-cause notice to the assessee as to why the difference between the stamp duty value of Rs. 84,55,500/- and the agreement value of Rs. 34,71,750/- should not be added as per section

Archana Muralidhar Bhandwalkar, Pune vs. Income Tax Officer Ward 5(2), Pune

In the result, appeal of the assessee is partly allowed

ITA 1840/PUN/2025[2016-17]Status: DisposedITAT Pune28 Nov 2025AY 2016-17

Section 147Section 148Section 148ASection 149Section 151Section 151ASection 250Section 271(1)(c)Section 56(2)(vii)Section 69A

Rs.5,57,760/- under section 56(2)(vii)(b) being deemed income on the ground that agreement value is less than the stamp duty value. The addition so made be deleted. The appellant be granted just and proper relief. 3. The Id CIT(A) failed to appreciate that the Rs.5

Archana Muralidhar Bhandwalkar, Pune vs. Income Tax Officer, Ward 5(2), Pune

In the result, appeal of the assessee is partly allowed

ITA 1615/PUN/2025[2016-17]Status: DisposedITAT Pune28 Nov 2025AY 2016-17

Bench: DR. DIPAK P. RIPOTE (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

Section 14Section 147Section 148Section 148ASection 149Section 151Section 151ASection 250Section 271(1)(c)Section 56(2)(vii)

Shri K.G Subbarama Setty, Bangalore vs. ACIT 5(2)(1) Bangalore, C R Building

In the result all the three appeals in ITA Nos

ITA 965/BANG/2025[2007-08]Status: DisposedITAT Bangalore28 Nov 2025AY 2007-08

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Sri Siddesh N Gaddi, A.RFor Respondent: Sri Balusamy N, D.R

Section 127Section 132Section 143(1)Section 143(2)Section 143(3)Section 154Section 250

guidance value of the property was @ Rs.5,110/- per sq.ft. as seen from the SRO’s registry for stamp duty value. The guidance value prescribed by the SRO from 1/04/2018 till 31/12/2018 WAS Rs.48,000/- per sq.mt. and thereafter the value prescribed is Rs.55,000/- per sq.mt. Converting the same ... sale consideration of villa no.13 was Rs.2,18,29,631/-. The 110% of the consideration received is Rs.2,40,12,594/- whereas the stamp duty value was only Rs.2,32,54,118/-and therefore we of theconsidered opinion that the actual sale consideration so received amounting to Rs.2

K A Sujit Chandan, Bengaluru vs. Assistant Commissioner of Income Tax Circle Bengaluru.-5(2)(1), Bengaluru

In the result all the three appeals in ITA Nos

ITA 964/BANG/2025[2007-08]Status: DisposedITAT Bangalore28 Nov 2025AY 2007-08

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Sri Siddesh N Gaddi, A.RFor Respondent: Sri Balusamy N, D.R

Section 127Section 132Section 143(1)Section 143(2)Section 143(3)Section 154Section 250

Dinesh Sunderrao Ghosalkar, Mumbai vs. ITO Ward 7(3) (1), Mumbai

In the result, appeal filed by assessee stands partly allowed for statistical purposes

ITA 4770/MUM/2025[2018-19]Status: DisposedITAT Mumbai28 Nov 2025AY 2018-19

Bench: Smt. Beena Pillai () & Smt. Renu Jauhri ()

Section 142(1)Section 143(2)Section 56(2)(x)

record, and liable to be quashed. 2. That the CIT(A) erred in holding that the difference between the agreement value and the stamp duty value (SDV) of the immovable property purchased by the appellant is taxable under Section 56(2)(x), without appreciating that the transaction was a bona ... submitted thus that, the seller agreed to sell the properties at a value of Rs. 2,81,43,500/- as against the stamp duty value of Rs. 3,56,73,152/-. The Ld. AR further submitted that, assessee purchased two industrial units situated at Parvati Industrial Estate, Lower Parel, Mumbai

Sonia Bhaskar, New Delhli vs. National Faceless Assessment Centre, Delhi

The appeal is dismissed

ITA 5649/DEL/2024[2018-19]Status: DisposedITAT Delhi28 Nov 2025AY 2018-19

Bench: Shri Anubhav Sharma & Shri Manish Agarwalsonia Bhaskar Vs. National Faceless Assessment B22 Maharani Baghi Centre Delhi- 110065 Delhi – 110002 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aabps2386J Appellant .. Respondent

For Appellant: NoneFor Respondent: Sh. Manish Gupta, Sr. DR

Section 143

scrutiny assessment and it was found that assessee along with two other persons has sold immovable property for Rs.24,65,00,000/- whereas stamp duty value of the same was Rs.37,32,71,500/-. On request of assessee the DVO report was called who had valued the property

Sonali Mahendra Naik Gaunekar, Panaji vs. Asst. Unit, NFAC, I. T. Department, Delhi

The appeal stands allowed for statistical purposes

ITA 312/PAN/2025[2016-17]Status: DisposedITAT Panaji27 Nov 2025AY 2016-17

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr Rahul Sarda [‘Ld. AR’]For Respondent: Mr Naveen Kumar [‘Ld. DR’]

Section 143(2)Section 147Section 148Section 250Section 253(1)Section 263Section 50CSection 50C(1)

fact that the date of the agreement fixing the amount of consideration preceded the date of registration of the agreement. Therefore, the stamp duty value as on the date of such agreement ought to have been considered for the purpose of section 50C(1) of the Act. 6. Since

Awadhnarayan Bhagwanta Singh, Mumbai vs. ITO 4(1)(2), Mumbai

In the result, the appeal of the assessee bearing ITA No

ITA 6045/MUM/2025[2017-18]Status: DisposedITAT Mumbai27 Nov 2025AY 2017-18

Bench: Shri Anikesh Banerjee & And Smt. Renu Jauhri

For Appellant: Shri Prakash JotwaniFor Respondent: Shri Surendra Mohan (SR DR)

Section 115BSection 143(1)Section 143(3)Section 250Section 56(2)(vii)

Section 56(2)(vii)(b) of the Act reveals the following: “56(2)(vii) ………………………… (b) Any immovable property,— (i) Without consideration, if the stamp duty value exceeds fifty thousand rupees, the stamp duty value of such property shall be considered. (ii) If acquired for consideration that is less than ... stamp duty value by an amount exceeding fifty thousand rupees, the portion of the stamp duty value exceeding such consideration shall be considered. Provided that where the date of the agreement fixing the amount of consideration for the transfer of immovable property and the date of registration

Paras Ramlal Jaiswar, Mumbai vs. ITO Ward-42(1)(4), Mumbai

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 5935/MUM/2025[2018-19]Status: DisposedITAT Mumbai27 Nov 2025AY 2018-19

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri Vikram Singh Yadavassessment Year : 2018-19 Paras Ramlal Jaiswar, Income Tax Officer, Flat No.4, Parijat Bldg, Ward-42(1)(4), Pandey Nagar, Raval Pada, Vs. Room No. 736, Dahisar East, Kautilya Bhavan, Maharashtra-400068. Bandra Kurla Complex, Pan : Afdpj3068H Mumbai-400051. (Appellant) (Respondent) For Assessee : Shri Devendra Jain For Revenue : Shri G.J. Ninawe, Sr.Dr Date Of Hearing : 27-11-2025 Date Of Pronouncement : 27-11-2025 O R D E R Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-National Faceless Appeal Centre (Nfac), Delhi [„Ld.Cit(A)‟], Dated 14-05-2025, Pertaining To Assessment Year (Ay) 2018-19, Wherein The Assessee Has Taken The Following Grounds Of Appeal:

For Appellant: Shri Devendra JainFor Respondent: Shri G.J. Ninawe, Sr.DR

Section 56Section 56(2)(x)

Faceless Appeal Centre (NFAC), CIT (Appeals) has erred in confirming the addition under section 56(2)(x) treating difference between Purchase Consideration and Stamp Duty Value as income and making addition of Rs. 3,40,412/- to the total Income of the appellant disregarding the factual and legal matrix ... case are that the assessee has purchased a property jointly with his wife for a transaction value of Rs. 45 lakhs, having stamp duty value of Rs. 51,80,824/-. During the course of assessment proceedings after calling for the necessary information and documentation, the amount

Mrs Rajani Jagannath Shetty, Mumbai vs. Assessing Officer 19 2 2, Mumbai

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

ITA 5780/MUM/2025[2018-2019]Status: DisposedITAT Mumbai27 Nov 2025AY 2018-2019

Bench: Shri Narender Kumar Choudhry, Jm Mrs. Rajani Jagannath Shetty Assessing Officer 19 2 2, A 3102, Ra Residence Opposite Mumbai Sharada Talkies, Dr. Babasaheb Vs. Ambedkar Road, Dadaw East, Mumbai – 400014. Pan/Gir No. Aqpps2210P (Appellant) : (Respondent) Assessee By : Shri Vimal Punmiya Respondent By : Shri Sandeep Jumale - Sr. Dr Date Of Hearing : 19.11.2025 Date Of Pronouncement : 27.11.2025 O R D E R Per Narender Kumar Choudhry, J M:

For Appellant: Shri Vimal PunmiyaFor Respondent: Shri Sandeep Jumale - SR. DR

Section 250Section 43CSection 56Section 56(2)

curative in nature and is therefore applicable to earlier assessment years also. It has held that when the difference between the stamp duty value and the sale consideration is less than 5% as per Section 56 r.w.s. 50C of the Act then the said marginal variation cannot be added ... assessee. Further, it held that the benefit of the availing 5% marginal difference in the variation between the sale consideration and the stamp duty value has to be extended to the assessee retrospectively, for the reason that the said amendment in the Finance Act, 2018 w.e.f. 01.04.2019 was curative

Savita Rameshchandra Mehta, Mumbai vs. Ward 41(1)(4), Mumbai

In the result, the appeal filed by the assessee is allowed for statistical purpose

ITA 5705/MUM/2025[2011-12]Status: DisposedITAT Mumbai27 Nov 2025AY 2011-12

Bench: Shri Narender Kumar Choudhry, Jm Savita Rameshchandra Mehta Ward 41(1)(4), Mumbai Flat No. 18, Hit Niketan Co-Op. Hsg. Soc. Sps Road, Kokan Nagar, Vs. Bhandup West, Mumbai – 400078. Pan/Gir No. Aahpm3210B (Appellant) : (Respondent) Assessee By : Shri R. L. Rathi Respondent By : Shri Praveen K. Srivastav, Sr. Dr Date Of Hearing : 19.11.2025 Date Of Pronouncement : 27.11.2025 O R D E R Per Narender Kumar Choudhry, J M:

For Appellant: Shri R. L. RathiFor Respondent: Shri Praveen K. Srivastav, SR

Section 143(3)Section 250Section 69B

part. However, the AO still made the addition of Rs. 11,65,500/- u/s. 69B of the Act being differential amount between the stamp duty value and consideration shown by the assessee in the agreement of property. 4. The Ld. Commissioner on appeal, though issued various notices to the Assessee

Dilip Dhirajlal Shah, Mumbai vs. ITO Ward 24(1)(1), Mumbai

In the result, appeal of the assessee is allowed for statistical purposes

ITA 5168/MUM/2025[2017-18]Status: DisposedITAT Mumbai27 Nov 2025AY 2017-18

Bench: Smt Beena Pillai & Smt.Renu Jauhri7 (A.Y.2017-18)

For Appellant: Shri Bharat Kumar RajpurohitFor Respondent: Shri Annavaran Kosuri- Sr. AR

Section 147Section 2(47)Section 250Section 56Section 56(2)Section 56(2)(vii)

view of the information available with the department regarding purchase of an immovable property for Rs. 1,41,74,000/- as against the stamp duty value (SDV) of Rs. 1,67,13,000/- the case was reopened u/s. 147 of the Act for the reason the income ... 5168/mum/2025. In addition, as per first proviso of section 56(2)(vii)(b), the Act is clear that the stamp duty value on the date of agreement may be considered. However, in the instant case, the appellant could not submit any supportive evidence of valuation report in order to substantiate