“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

Sanjeev Kumar, Ropar, Punjab vs. Ward-2(2), Ropar, Punjab

ITA 303/CHANDI/2025[2014-15]Status: DisposedITAT Chandigarh19 Jan 2026AY 2014-15

Bench: Shri Laliet Kumar & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 303/Chd/2025 "नधा"रण वष" / Assessment Year : 2014-15 Sanjeev Kumar, The Ito, M/S Khurana Filling Station, बनाम Ward 2(2), Chamkaur Sahib, Ropar Vs. Distt. Ropar, Punjab 140121 "थायी लेखा सं./ Pan No: Ajppk8321E अपीलाथ"/Appellant ""यथ"/Respondent (Physical Hearing) "नधा"रती क" ओर से/Assessee By : Sh. Parikshit Aggarwal, Ca राज"व क" ओर से/ Revenue By : Dr.Ranjit Kaur, Addl. Cit, Sr. Dr

For Appellant: Sh. Parikshit Aggarwal, CAFor Respondent: Dr.Ranjit Kaur, Addl. CIT, Sr. DR

Section 56(2)(vii)

Worthy CIT(A) has erred in confirming the addition of Rs. 48,00,000/- made by Ld. AO on account of difference in stamp duty value and actual purchase value even when the actual purchase value of property was genuine u/s 56(2)(vii)(b) of the Act. 3. That

Swapnal Subhash Anbhavane, Mumbai vs. ITO Ward 41(1)(5), Mumbai

In the result, appeal filed by assessee stands allowed

ITA 7191/MUM/2025[2017-18]Status: DisposedITAT Mumbai19 Jan 2026AY 2017-18

Bench: Smt. Beena Pillai ()

Section 148Section 148ASection 270ASection 56(2)(vii)

assessee. The Ld.AO was of the opinion that there was difference of Rs.95,49,361/- between agreement value as well as the stamp duty value. 2.1. After completing the due procedure under the new provisions of Section 148A notice u/s 148 was issued on 31/07/2022. The assessee was thereafter called ... because the consideration is paid according to the direction of the Consumer Court the transaction would not become tax-free for adopting the stamp duty value for the entire year. The Ld.AO thus, called upon the assessee to explain as to why provisions of Section

Mayur Kanubhai Shah, Mumbai vs. ITO Ward 1992)(2), Mumbai

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

ITA 5600/MUM/2025[2016-17]Status: DisposedITAT Mumbai19 Jan 2026AY 2016-17

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

For Appellant: Shri Rishav PatawariFor Respondent: Shri Ritesh Misra (CIT DR)

Section 143(3)Section 2(14)(iii)Section 250Section 56Section 56(2)(viib)

During the assessment proceeding the Ld. AO asked the assessee for explanation related to difference of agreement value and the stamp duty value of the property which will contravening provision of section 56 (2)(viib) of the Act. The assessee complied & explained that the assessee purchased the said

Renu Bothra, Kolkata vs. DCIT, Circle 46, Kolkata

In the result, appeal of the assessee is allowed

ITA 2687/KOL/2025[2018-2019]Status: DisposedITAT Kolkata14 Jan 2026AY 2018-2019

Bench: SHRI GEORGE MATHAN (Judicial Member)

For Appellant: Shri Anil Kochar, ARFor Respondent: Smt. Sima Das Biswas, Sr. DR

Section 56(2)(x)

which exceeds fifty thousand rupees, the whole of the aggregate value of such sum; (b) any immovable property, - (A) without consideration, the stamp duty value of which exceeds fifty thousand rupees, the stamp duty value of such property;- (B) for a consideration, the stamp duty value of such property ... time frame for implementing this enhancement of tolerance band or safe harbour provision. The reasons assigned by the CBDT, i.e., "the variation between stamp duty value and actual consideration received can occur in respect of similar properties in the same area because of a variety of factors, including the shape

Laljibhai Parshottambhai Gaudani, Ahmedabad vs. The Dy.CIT, Circle-3(1)(1), Ahemdabad

ITA 1238/AHD/2025[2012-13]Status: DisposedITAT Ahmedabad13 Jan 2026AY 2012-13

Bench: Ms. Suchitra Raghunath Kamble & Shri Narendra Prasad Sinhaassessment Year:2012-13

Section 143Section 143(3)Section 148Section 2(47)(v)Section 27(1)(c)Section 50CSection 50C(5)Section 53A

assessee submitted that the assessee had sold a plot No. 61 at Rajpathnagar Association for a consideration of Rs.14,59,860/-, the stamp duty value of which was Rs. Laljibhai Parshottambhai Gaudani vs. DCIT, A.Y 2012-13 4 59,90,320/-. He submitted that the agreement for sale of property ... that this fact was brought to the knowledge of AO in the course of assessment proceedings and a request was made that the stamp duty value of the property as on the date of agreement i.e. as on 03.10.2004 should be considered in accordance with the proviso to section

Vijay Balbhim Pise, Solapur vs. ITO Ward 1(2), Solapur

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

ITA 195/PUN/2025[2014-15]Status: DisposedITAT Pune12 Jan 2026AY 2014-15

Bench: Dr. Manish Borad & Ms. Astha Chandraआयकर अपील सं. / Ita No.195/Pun/2025 धििाारण वर्ा / Assessment Year: 2014-15 Vijay Balbhim Pise, Vs Ito Ward 1(2), 110, Railway Lines, Solapur- Solapur 413001 Maharashtra Pan-Ajgpp4660A Appellant Respondent

For Appellant: Shri Kushal Soni (Virtual)For Respondent: Shri Aviyogi Ambadkar

Section 143(3)Section 250Section 271(1)(c)Section 50C

others, the sale consideration shown in the sale agreement is Rs. 37,50,000/- but the Stamp Valuation authorities have calculated the stamp duty valued at Rs. 1,14,50,000/- There is a difference of Rs. 77,00,000/- in between the stamp duty valuation of property

Balkrishna Pandurang Patil, Mumbai vs. Ward No 10(3)(1), Mumbai

ITA 5083/MUM/2025[2017-18]Status: DisposedITAT Mumbai12 Jan 2026AY 2017-18

Bench: SHRI NARENDER KUMAR CHOUDHRY (Judicial Member)

For Appellant: Shri Ashwin Chhag, Ld. A.RFor Respondent: Shri Praveen K. Srivastav, SR. D.R

Section 250

Mumbai to the effect “that the Assessee has sold a property showing the sale consideration of Rs.32,00,000/- whereas the stamp duty value

Assisstant Commissioner of Income Tax, Jhandewalan Extn vs. Om Prakash Arora, Connaught Place

In the result, appeal of the Revenue vide ITA No

ITA 5031/DEL/2024[2015-16]Status: DisposedITAT Delhi09 Jan 2026AY 2015-16

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2015-16] Assistant Commissioner Of Om Prakash Arora, Income Tax, Central Circle-01, M-3, Flat No.103, Avg Bhawan E-2, Jhandewalan Extn. Vs The Variety Books Depot. New Delhi-110055 Connaught Place, New Delhi-110001 Pan-Accpa9774F Assessee Revenue Cross Objection No.42/Del/2025 (Arising Out Of Ita No.5031/Del/2024) [Assessment Year: 2015-16] Om Prakash Arora, Assistant Commissioner Of Income M-3, Flat No.103, Avg Tax, Central Circle-01, Bhawan The Variety Books Vs E-2, Jhandewalan Extn. Depot. Connaught Place, New Delhi-110055 New Delhi-110001 Pan-Accpa9774F Assessee Revenue [Assessment Year: 2016-17] Assistant Commissioner Of Om Prakash Arora, Income Tax, Central Circle-01, M-3, Flat No.103, Avg Bhawan E-2, Jhandewalan Extn. Vs The Variety Books Depot. New Delhi-110055 Connaught Place, New Delhi-110001 Pan-Accpa9774F Assessee Revenue

Section 139(1)Section 143(3)Section 147Section 148Section 151

that the actual consideration was more than the disclosed sale consideration. In the instant case neither of the two conditions are met. The stamp duty value as on the said date was Rs. 2,10,85,000/- (4217 Sq. Ft. x Rs. 5,000 per Sq. Ft.). Relevant extracts

Assisstant Commissioner of Income Tax, Jhandewalan Extn vs. Om Prakash Arora, Connaught Place

In the result, appeal of the Revenue vide ITA No

ITA 5029/DEL/2024[2016-17]Status: DisposedITAT Delhi09 Jan 2026AY 2016-17

Section 139(1)Section 143(3)Section 147Section 148Section 151

Pratish Shah (HUF), Surat vs. ITO, Ward 1(2)(1), Surat

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

ITA 1113/SRT/2025[2018-19]Status: DisposedITAT Surat08 Jan 2026AY 2018-19

Bench: Shri Sanjay Gargshri Narendra Prasad Sinha

For Appellant: Shri Rajesh C Shah, ARFor Respondent: Shri Ajay Uke, Sr. DR

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

Assessing Officer found that the assessee had purchased an immovable property during the year for a consideration of Rs.63,24,500/-. However, the stamp duty value of the property was 87,81,709/-. The difference of Rs.24,57,209/- was considered as other income and added under the provision ... thus agreed to purchase the property on 18.02.2013 itself, when the first payment was made by him. The Ld. AR submitted that the stamp duty value of the property as on date of the agreement i.e. on 18.02.2013 should have been considered by the Assessing Officer for making the addition

Smt. Nileshwar Jayanthi Prabhu L/R of Late Sri. Nileshwar Damodar Prabhu, Bengaluru vs. DCIT, Circle-1(1)(1), Bangalore

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

ITA 1697/BANG/2025[2017-18]Status: DisposedITAT Bangalore08 Jan 2026AY 2017-18

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year : 2017-18

For Appellant: Shri Pranav Krishna, AdvocateFor Respondent: Shri Subramanian .S, JCIT-DR

Section 142(1)Section 143(1)Section 143(2)Section 147Section 148Section 250Section 50CSection 57

based on the information that the assessee had sold an immovable property for a consideration which Page 3 of 5 is below the stamp duty value of the property, the case was reopened u/s. 147 of the Act and notice u/s. 148 was issued. The assessee also filed his return ... invoked section 50C/43CA of the Act on the ground that the sale consideration shown by the assessee is below the stamp duty value of the property. The legal heir of the deceased assessee filed her reply and submitted that the difference amount of Rs. 25,51,000/- was already shown

Material Research Instruments, Mumbai vs. ACIT-Circle16(2), Mumbai

In the result, the appeal of the assessee is partly allowed

ITA 4084/MUM/2025[2006-07]Status: DisposedITAT Mumbai08 Jan 2026AY 2006-07

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 147Section 50C

jurisdiction under section 147 as well as the additions made on merits, 2 Material Research Instruments particularly in relation to the adoption of stamp duty value as the full value of consideration under section 50C and the determination of cost of acquisition as on 01.04.1981 for the purposes of computing ... premise that the document was registered in the year 2009, the Assessing Officer invoked the provisions of section 50C by adopting the stamp duty value prevailing as on the date of registration and further rejected the assessee’s valuation of the cost of acquisition, substituting the same with an estimated

Sarayu Krishna Kamat, Piramal Chamber vs. DCIT Circle 22(1), Piramal Chamber Mumbai

In the result the appeal of the assessee bearing ITA No

ITA 6738/MUM/2025[2018-19]Status: DisposedITAT Mumbai07 Jan 2026AY 2018-19

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

For Appellant: Shri Sampat NagapFor Respondent: Shri Swapnil Choudhary (SR AR)

Section 143(3)Section 250Section 56(2)Section 56(2)(x)

related to A.Y. 2017-18 is the correct implication of the Act. The Ld. AR further stated that difference of stamp duty value of and the set forth value is lesser than the 10% so addition is illegal U/s 56(2) of the Act. But without considering the same ... clear that the assessee's case is squarely covered by the 1st proviso to section 56(2)(x) of the Act the stamp duty value applicable in her case would be as on the date of agreement, which is 23/08/2017, which makes her liable to be covered under the provisions

Ck International Pvt Ltd, Delhi vs. ITO, Ward-6(1), Delhi

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

ITA 677/DEL/2025[2019-20]Status: DisposedITAT Delhi07 Jan 2026AY 2019-20

Bench: Shri S Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Satyen Sethi & A.T. PandaFor Respondent: Shri Om Prakash, Sr. DR

Section 139Section 142Section 143(1)Section 143(1)(a)Section 250Section 50CSection 50C(1)Section 56(2)(vii)

passed by Ld. AO making adjustment of Rs.14,68,000/- under the head “Long Term Capital Gains” on account of adopting stamp duty value instead of sales consideration of immoveable property sold. 3. Against order dated 06.07.2020 of Ld. AO, the appellant/assessee filed appeal before Ld. CIT(A) which ... deeming provision. Though, sub-section (1) of section 50C ITA No. 1024/Del./2022 AY: 2019-20 provides for substituting the stamp duty value as deemed sale consideration in place of the declared sale consideration, however, sub- section (2) carves out an exception by providing that if the assessee objects

Income Tax Officer(E) Ward- 2(4), New Delhi, Civic Centre New Delhi vs. Prakash Sewa Trust, Paschim Vihar

ITA 4305/DEL/2024[2016-17]Status: DisposedITAT Delhi07 Jan 2026AY 2016-17

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 11Section 12ASection 143(3)

reference to Section 56(2)(x) of the Act, it did not mention whether the Assessing Officer proposed to treat the stamp duty value as deemed Income of assessee under clause (a) or clause (b) of Section 56(2)(x) of the Act. This is because both are separate provisions ... under either of these two clauses the stamp duty value could be treated as deemed income. By not specifying whether Section 56(2)(x)(a) or Section 56(2)(x)(b) of the Act was applicable, the A.O. first of all has not given reasonable opportunity of showing cause

Smita, Ranchi vs. ITO Ward 3(4), Chaibasa

The appeal of the assessee is allowed

ITA 266/RAN/2025[2018-19]Status: DisposedITAT Ranchi06 Jan 2026AY 2018-19

Bench: SHRI SONJOY SARMA, JUDICIAL MEMBER SHRI RATNESH NANDAN SAHAY (Accountant Member)

Section 144BSection 147Section 148Section 151

issued on the ground that the assessee had sold a flat for a consideration of ₹30 lakhs, whereas the stamp duty value as per State valuation authority was ₹46.50 lakhs, resulting in alleged escapement of income chargeable to tax.The Assessing Officer completed reassessment by adopting the stamp duty valuation

Naveen Singh, Jamshedpur vs. Deputy Commissioner of Income Tax, Circle - 1, Jamshedpur

In the result, the appeal of the assessee is allowed

ITA 413/RAN/2024[2017-18]Status: DisposedITAT Ranchi06 Jan 2026AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.413/Ran/2024 Assessment Year: 2017-18 Naveen Singh………...…………….…….…............................……….……Appellant M-9 Old, Adityapur Jamshedpur, Jharkhand- 831013. [Pan: Adkps4229A] Vs. Dcit, Circle-1, Jamshedpur.….....…..…..….........……........……...…..…..Respondent Appearances By: Shri P. S. Paul, Ca, Appeared On Behalf Of The Appellant. Shri Sumit Dasgupta, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 18, 2025 Date Of Pronouncing The Order : January 06, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Nfac, Delhi (Hereinafter Referred To As “Cit(A)”) Dated 12.09.2024 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”). 2. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income For Assessment Year 2017–18 Declaring A Total Income Of ₹43,99,340/- Under Section 139(1) Of The Act. The Return Was Processed Under Section 143(1) Accepting The Income As Declared. Subsequently, The Ao Issued A Notice Under Section 148 Of The Act After Recording Reasons & Obtaining Sanction From The Competent Authority. The Assessee Did Not Respond To The Notice Under Section 148. Thereafter, Multiple Notices Under Section 142(1) Were Issued, Including Final Opportunity Notices, Which Were Duly Served But Remained Unanswered.

Section 139(1)Section 142(1)Section 143(1)Section 144Section 147Section 148Section 250Section 56(2)(x)

assessee acquired only leasehold rights and superstructure, that too as one of three purchasers. Hence, the adoption of ₹7,64,10,000 as stamp duty value is factually and legally incorrect. A remand report was called from the AO vide letter dated 26.11.2024 in the remand report the AO could ... r.w.s. 148 to reopen the assessment does not satisfy the requirements of the law. 8. Even on merits, we find that the stamp duty value legally applicable is ₹2,25,59,000, being value of superstructure only. since no land ownership was transferred, the assessee was only a one-third

Gauri Shivajirao Jadhav, Pune vs. The Income Tax Officer, Ward 9(1), Pune

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

ITA 1646/PUN/2025[2018-19]Status: DisposedITAT Pune05 Jan 2026AY 2018-19

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1646/Pun/2025 िनधा"रण वष" / Assessment Year : 2018-19 Gauri Shivajirao Jadhav, Vs. Ito, Ward-9(1), Pune. Seva, 678, Nere Nr. Iims College, Jambe Mulshi, Pune- 411033. Pan : Bdppj8217B Appellant Respondent Assessee By : Shri Ajay Rander Revenue By : Shri Uodol Raj Singh Date Of Hearing : 13.11.2025 Date Of Pronouncement : 05.01.2026 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 17.01.2025 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2018-19. 2. There Is Delay In Filing Of The Present Appeal. We Are Satisfied With The Reasons Mentioned In The Application For Condonation Of Delay Duly Supported By An Affidavit That The Applicant Was Prevented By Sufficient Cause For Not Filing The Appeal Within The Prescribed Time Limit. After Hearing Ld. Dr, We Condone The Delay & Proceed To Adjudicate The Appeal.

For Appellant: Shri Ajay RanderFor Respondent: Shri Uodol Raj Singh

Section 142(1)Section 144Section 147Section 148

considering that by submission of Valuation Report in support of the agreement value of the transaction, the appellant had disputed that Stamp Duty Value and there was a case for making reference to Valuation Officer for determining the Fair Market Value of the Property? 4. Whether on the facts

Jewelex India Priavte Limited, Mumbai vs. DCIT Circle-14(1)(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 5285/MUM/2025[2020-21]Status: DisposedITAT Mumbai05 Jan 2026AY 2020-21

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarjewelex India Private V/S. Deputy Commissioner Of Limited बनाम Income Tax, Circle – 401 Trade Centre, Bandra 14(1)(1), Aayakar Bhavan, Kurla Complex, Bandra Maharishi Karve Marg, (East), Mumbai – 400 098, Mumbai – 400 020, Maharashtra Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aabcj4523H Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri Nitesh Joshi, ARFor Respondent: Ms. Kavitha Kaushik, (Sr. DR)

Section 135Section 143(3)Section 37Section 37(1)Section 43(6)(c)Section 80G

deleted. 2. The learned Commissioner of Income-tax (Appeals) erred in upholding the adjustment made by the Assessing Officer by reducing stamp duty value of Rs. 83,40,922/-instead of actual sale consideration of Rs. 75,16,017/- from block of assets. 3. It is submitted that the reduction ... no.2 and 3,the assessee has claimed that the ld.CIT(A) erred in upholding the adjustment made by the Assessing Officer by reducing stamp duty value of Rs. 83,40,922/-instead of actual sale consideration of Rs. 75,16,017/- from the Bock of assets. It is submitted that

Mukesh Vaikunthlal Mehta, Mumbai vs. Income Tax Officer Ward 34(2)(1), Mumbai

ITA 4669/MUM/2025[2011-12]Status: DisposedITAT Mumbai01 Jan 2026AY 2011-12

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Ms. Sailee GujrathiFor Respondent: Shri Annavaran Kosuri

Section 14(3)Section 143(1)Section 143(3)Section 147Section 148Section 50CSection 54

property and (iv) area consideration paid to tenants/ owners /occupants enjoying the property. Such full value of consideration should be compared with the stamp duty value arrived by the DVO to determine applicability of section 50C of the Act. Further, the amount paid to the tenants/ other owners and occupants ... appellant in the computation of capital gains. Since the aggregate consideration paid by the buyer for the entire property far exceeds the stamp duty value, there is no question of applying provisions of section 50C of the Act. Hence, the appellant prays that such addition may be deleted