“full value of consideration”

Capital GainsSection 48Section 48587 judgments

The decision most relied on for full value of consideration is CIT v. George Henderson & Co. Ltd. (66 ITR 622), cited in 82 judgments on BharatTax.

Leading authorities on full value of consideration

CIT v. George Henderson & Co. Ltd.

66 ITR 622 · 1967 · Supreme Court

citing judgments

The 'full value of consideration' for computing capital gains under Section 48 of the Income Tax Act, 1961 (or its predecessor, Section 12B of the 1922 Act), means the actual price bargained for and received or accrued by the parties. It does not refer to the market value or any notional value of the asset transferred.

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.

CIT v. Smt. Nilofer I. Singh

309 ITR 233 · 2009 · High Court

citing judgments

The full value of consideration for computing capital gains under Section 48 refers to the amount stated in the sale deed and cannot be substituted by the market value or a valuation by the DVO under Section 55A, unless there is evidence that the assessee actually received a consideration in excess of the stated amount.

CIT v. Gillanders Arbuthnot & Co.

87 ITR 407 · 1973 · Supreme Court

citing judgments

The "full value of the consideration" for computing capital gains under Section 48 of the Income Tax Act, 1961 (or Section 12B(2) of the 1922 Act), means the price actually bargained for and agreed to by the parties, not the market value of the asset transferred. In a sale transaction involving a price, the market value of the consideration is not relevant.

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).

CIT v. Mother India Refrigeration Industries (P.) Ltd.

155 ITR 711 · 1985 · Supreme Court

citing judgments

Legal fictions and deeming provisions are created for definite purposes and must be limited strictly to that purpose, not extended beyond their legitimate field or the explicit mandate of the section. This principle requires strict interpretation of such provisions.

CIT v. Shakuntala Kantilal

190 ITR 56 · 1991 · High Court

citing judgments

Payments made by an assessee to release property from an encumbrance or settle disputes, which are essential for a sale transaction to materialize, are allowable as a deduction under Section 48 of the Income-tax Act for computing capital gains. Such expenditure either reduces the full value of consideration or is deductible from it.

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.

Judgments citing full value of consideration

Kishore Anand Shetty, Goregaon East Mumbai vs. Circle 32(2), Mumbai

In the result, both the appeals of the assessee are allowed in terms indicated above

ITA 4975/MUM/2025[2014-15]Status: DisposedITAT Mumbai09 Feb 2026AY 2014-15

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 143(3)Section 271(1)(c)Section 50CSection 54F

declared consideration and the stamp duty valuation, invoked the deeming provisions of section 50C and substituted the proportionate stamp duty value as the full value of consideration, thereby making an addition of ₹13,47,925/-. 6. Before the learned Commissioner of Income-tax (Appeals), the assessee categorically contended that

Kamleshbhai Manubhai Patel, Vadodara vs. The Dy.CIT, Circle-1(1)(1), Vadodara

The appeal of the Assessee is partly allowed for statistical purpose

ITA 814/AHD/2025[2012-13]Status: DisposedITAT Ahmedabad05 Feb 2026AY 2012-13

Bench: Shri Tr Senthil Kumar & Shri Narendra Prasad Sinhaassessment Year: 2012-13

Section 143(3)Section 50C

value adopted or assessed by the stamp valuation authority on the date of agreement shall be taken for the purpose of computing full value of consideration for such transfer. In the present case the agreement for sale was made vide registered banakhat dated 11.04.2011. Therefore, the AO was required

Monica Bibbly Sood, Chandigarh vs. Income Tax Officer, Ward 1(3), Chandigarh

In the result, appeal is allowed

ITA 78/CHANDI/2025[2013-14]Status: DisposedITAT Chandigarh03 Feb 2026AY 2013-14

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकरअपीलसं./ Ita No. 78/Chd/2025 "नधा"रणवष" / Assessment Year: 2013-14 Monica Bibbly Sood, The Ito, # 131, Sector 4, Vs Ward 1(3), Mdc, Panchkula. Chandigarh. "थायीलेखासं./Pan No: Alsps4022P अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Harry Rikhy, Advocate Revenue By : Dr. Ranjit Kaur, Addl. Cit Sr. Dr Date Of Hearing : 28.01.2026 Date Of Pronouncement : 03.02.2026 Hybrid Hearing O R D E R

For Appellant: Shri Harry Rikhy, AdvocateFor Respondent: Dr. Ranjit Kaur, Addl. CIT Sr. DR

Section 48Section 50C

valuation would be considered as a deemed full sale consideration contemplated in Section 48 of the Income Tax Act. In other words, the full value of consideration provided in Section 48 would be replaced by the amount on which Stamp Duty is being charged from the assessee. The only condition ... dispute in the present appeal. The dispute relates to 1st and 2nd proviso to Section 50C which contemplates as under : Special provision for full value of consideration in certain cases.- 50C (1) ............ [Provided that where the date of the agreement fixing the amount of consideration and the date of registration

Madhukar Ganpat Dhakwal, Mangaon vs. Income Tax Officer, Ward 5, New Panvel

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

ITA 2434/PUN/2025[2018-19]Status: DisposedITAT Pune03 Feb 2026AY 2018-19

Bench: Shri Rama Kant Panda & Shri Vinay Bhamoreआयकर अपील सं / Ita No.2434 & 2418/Pun/2025 धििाारण वषा /Assessment Year: 2018-19 Madhukar Ganpat Ito, Ward 8(5), Dhakwal, Raigad 1/B At Tilore Post Vs. Vighawali Tal Mangaon, Wighawali B.O Tilore, Raigarh Maharashtra Pan-Bfopd7627G अपीलार्थी / Appellant प्रत्यर्थी/Respondent Assessee By: Ca Hiral D. Sejpal & Ankita P. Gorde Department By: Smt. Sonal L Sonkavde, Addl-Cit Date Of Hearing: 03-02-2026 Date Of Pronouncement: 16-03-2026 आदेश/Order Per Shri Vinay Bhamore: These Two Appeals Filed By The Assessee Are Directed Against The Same Order Dated 25.08.2025 Passed By Ld. [Cit(A)] Nfac, Delhi For The Assessment Year 2018-19. 2. Assessee Has Raised Following Grounds Of Appeal:-

For Respondent: Smt. Sonal L Sonkavde

Section 147Section 148Section 148ASection 151Section 250Section 50C

without considering: 6.1.1. The stamp duty value of the land is not Rs. 63,65,000/- 6.1.2. The full value of consideration of the land is Rs. 20,00,000/- 6.1.3. The land is held for more than 24 months 6.1.4. The Indexed cost of acquisition of the land

Madhukar Ganpat Dhakwal, Pune vs. Income Tax Officer Ward 8(5), Raigad

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

ITA 2418/PUN/2025[2018-19]Status: DisposedITAT Pune03 Feb 2026AY 2018-19

For Respondent: Smt. Sonal L Sonkavde

Section 147Section 148Section 148ASection 151Section 250Section 50C

Aero Pack Products Private Limited, Navi Mumbai vs. Income Tax Officer, Mumbai

In the result, the appeal of the assessee is allowed in the manner indicated above

ITA 6697/MUM/2025[2022-23]Status: DisposedITAT Mumbai30 Jan 2026AY 2022-23

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI MAKARAND VASANT MAHADEOKAR (Accountant Member)

Section 143(1)Section 50CSection 56(2)(x)

assessed by the stamp valuation authority does not exceed the prescribed margin of 10%, the declared consideration shall be deemed to be the full value of consideration. 7. Applying the said statutory tolerance to the facts of the present case, once the fair market value as determined

Nayana Jayesh Patel, Indore vs. Assessing Officer, Indore

Appeal is allowed for statistical purpose

ITA 475/IND/2025[2012-13]Status: DisposedITAT Indore22 Jan 2026AY 2012-13

Bench: Shri B.M. Biyani

Section 147Section 250Section 50c

passed a fresh assessment order dated 19.03.2022 u/s 147 r.w.s. 263 & 144B assessing capital gain from sale of immovable property as under: Full value of consideration Rs. 1,60,00,000/- Value of property at per section 50C as on date of Registered Sale: For 1st Property ... computation of income LTCG Rs. 1,85,94,875/- However, the assessee was aggrieved by the full value of consideration of Rs. 2,30,26,000/- (+) Rs. 2,30,00,000/- aggregating to Rs. 4,60,26,000/-, adopted by AO in above computation on the basis of section

Milan Theatres P Limited, Mumbai vs. DCIT Circle 12(3)(2), Mumbai

ITA 5072/MUM/2024[2017-18]Status: DisposedITAT Mumbai22 Jan 2026AY 2017-18

Section 143(3)Section 342Section 45(2)

IN THE INCOME TAX APPELLATE TRIBUNAL, ‘D’ BENCH MUMBAI BEFORE: SHRI AMIT SHUKLA, JUDICIAL MEMBER & SHRI ARUN KHODPIA, ACCOUNTANT MEMBER

Radhika Jewellers, Rajkot vs. Dy.CIT 2 (1), Rajkot

In the result, appeal filed by the assessee is allowed

ITA 568/RJT/2025[2015-16]Status: DisposedITAT Rajkot20 Jan 2026AY 2015-16

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

For Appellant: Shri Samir Jani, Ld. ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)

Section 142(1)Section 143(2)Section 143(3)Section 250Section 45Section 45(3)

provisions of section 45(3) of the Act are attracted and the value recorded in the books of the firm is treated as full value of consideration for the purpose of computing capital gain. Accordingly, the capital gain was worked out at Rs.43 ... case, the provisions of section 45(3) are attracted and the value recorded in the books of the firm is treated as full value of consideration for the purpose of computing capital gain. Accordingly, the capital gain is worked out at Rs.43

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

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 long-term capital gains ... adopted or assessed or assessable by the stamp valuation authority on the date of agreement may be taken for the purposes of computing full value of consideration for such transfer; Provided further that the first proviso shall apply only in a case where the amount of consideration, or a part

Murtuza Kothari, Mumbai vs. Income Tax Officer Ward 19(2)(2), Mumbai

Accordingly, ground nos. 1 & 2 of the assessee are partly allowed for

ITA 4080/MUM/2025[2015-16]Status: DisposedITAT Mumbai06 Jan 2026AY 2015-16

Bench: Shri Amit Shukla, Jm & Shri Arun Khodpia, Am

For Appellant: Shri Suresh Otwani, ARFor Respondent: Shri Annavaran Kosuri, Sr. DR

Section 142(1)Section 143(2)Section 147Section 148Section 148ASection 48Section 49Section 50CSection 54

other documents. After analysing the aforesaid information furnished before the AO, it is observed by the AO that the assessee has disclosed full value of consideration adopted under section 50C of the Act for the purpose of capital gain at Rs. 86,00,000/- and a deduction was claimed under ... further analysis of computation of Long Term Capital Gain, it was noticed that the assessee disclosed full value of consideration adopted as per section 50C for the purpose of Capital Gains of Rs. 86,00,000/-, deduction claimed u/s 48 of the Act of Rs. 83,62,976/- as cost

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

United Marine Academy (2011) 51 DTR 241 (Bom), among others, to hold that in view of section 50C of the Act, the “full value of consideration” is deemed to be the stamp duty valuation in the case of transfer of land or building, and such deemed consideration ... block of assets when the asset transferred is land or building. Once the statute mandated substitution of the stamp duty valuation as the “full value of consideration”, the same must be applied consistently for purposes of section 43(6)(c) of the Act as well. The reliance placed

Madhur Coal Mining Pvt. Ltd., Kolkata vs. D.C.I.T., Circle - 8(1), Kolkata

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

ITA 1784/KOL/2025[2015-2016]Status: DisposedITAT Kolkata02 Jan 2026AY 2015-2016

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 143(2)Section 143(3)Section 250Section 50DSection 56(2)(viia)

therefore held the fair market value (FMV) of the shares on the date of transfer will be deemed to be the full value of consideration as per provisions of section 50D. He computed capital gain taxable as per provisions of section 50D at Rs 5,24,71,800/-. 8.6.4 During ... asset is not ascertainable or cannot be determined, the fair market value on the date of transfer shall be deemed to be the full value of consideration. The provision is designed to address cases where the declared consideration either does not reflect the actual transaction value or is incapable

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

deleted. 3. Without prejudice to the grounds numbers 1 and 2 above, the honorable CIT(A) failed to appreciate that the full value of consideration accruing as a result of transfer of the property should be the aggregate consideration paid by the buyer, i.e.: (i) monetary consideration paid ... monetary consideration paid to tenants/ owners/occupants enjoying the 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

Vikas Jain, Kanpur vs. ACIT-CC 2(1)(1), Kanpur

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

ITA 434/LKW/2024[2015-16]Status: DisposedITAT Lucknow31 Dec 2025AY 2015-16

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharya.Y. 2015-16 Vikas Jain, Vs. The Acit, H-2/1, Kidwai Nagar, Kanpur- Circle 2(1)(1), Kanpur 208001 208006 Pan: Abqpj8049R (Appellant) (Respondent) Assessee By: Sh. Rakesh Garg, Adv Revenue By: Sh. Amit Kumar, Dr Date Of Hearing: 07.10.2025 Date Of Pronouncement: 31.12.2025 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed By The Assessee Against The Orders Of The Ld. Cit(A), Nfac On 17.05.2024 Wherein The Ld. Cit(A) Has Dismissed The Appeal Of The Assessee Against The Order Passed By The Ld. Assessing Officer Under Section 147 R.W.S. 143(3) For The A.Y. 2015-16 On 27.12.2018. The Grounds Of Appeal Are As Under:- “01. Because There Being No Reason To Believe, Far From There Being Any Material To Form Reasons To Believe, The Proceedings Initiated Right From Issue Of Notice U/S. 148 & The Re-Assessment Framed Thereof Are All Without Jurisdiction Bad In Law, The Order Passed Be Quashed. 02. Because The So-Called Reasons Having Been Recorded Applying Explanation 2(A) To Section 147, Of The Act Which Not Being Applicable, The Very Reason To Believe Being Contrary To The Mandate Of The Section, The Proceedings- Initiated U/S 148, The Reassessment Framed Are All Contrary To The Provisions Of Law, Be Quashed. 03. Because The Approval Given By The Competent Authority U/S 151, Being Mechanical In Nature Without Verification Of Facts, The Notice Issued U/S 148 & The Reassessment Framed Thereafter Be Quashed.

For Appellant: Sh. Rakesh Garg, AdvFor Respondent: Sh. Amit Kumar, DR

Section 143(1)Section 147Section 148Section 151Section 156Section 48Section 50C

assessed by the stamp duty authority would, for the purposes of section 48 of the Income Tax Act, be deemed to be the full value of consideration received on transfer of an asset. Accordingly, applying the provisions of section 50C, he held reasons to believe that assessee’s income chargeable ... open market and therefore, the fair market value as determined by the Valuation Officer could not be deemed to be the full value of consideration in such circumstances. It was pointed out that the property was under a 30-year lease to Reliance Industries Limited and the assessee

Vanraj Ranchhoddas Merchant (Through Legal Heir Harshit Merchant), Mumbai vs. ITO Ward 30(1)(1), Mumbai

In the result the appeal of the assessee is partly allowed

ITA 5234/MUM/2025[2011-12]Status: DisposedITAT Mumbai29 Dec 2025AY 2011-12

Bench: Smt. Beena Pillai & Shri Makarand Vasant Mahadeokar

Section 133(6)Section 143(1)Section 143(3)Section 147Section 148Section 250Section 50CSection 54F

principles. 11. Accordingly, the Ld. CIT(A) partly allowed the appeal and directed the Assessing Officer to adopt Rs.80,04,300/- as the full value of consideration for computing long-term capital gains, instead of Rs.1,11,07,000/-, and to recompute the capital gains after allowing exemption under section ... equated merely because both relate to immovable property. 29. Section 50C is a deeming provision which substitutes the stamp duty value as the full value of consideration where the capital asset transferred is land or building or both. It is a settled principle of interpretation that a deeming fiction must

Yogendra Sharma, Delhi vs. Income Tax Officer, Etah

In the result, the appeal preferred by assessee is allowed

ITA 408/AGR/2025[2012-13]Status: DisposedITAT Agra19 Dec 2025AY 2012-13

Bench: : Shri S. Rifaur Rahmanassessment Year: 2012-13 Yogendra Sharma, I-4695, 2Nd Vs. Income-Tax Officer, Floor, Gali No. 4-B, Balbir Nagar Ward 3(2), Etah. Extension, Shahdara, Delhi. Pan :Cgkps6492J (Appellant) (Respondent)

Section 143(2)Section 143(3)Section 147Section 148Section 50C

stamp duty value of the sold property. Accordingly, he treated the same as short term capital gains by determining the same as under : Full Value of consideration (as per section 50C) Rs.8,40,000/- Cost of acquisition Rs.1,07,200/- Cost of improvement Rs.5,00,000/- Short term capital gains ... registered sale deed or, where applicable, the value adopted/assessed for stamp duty purposes under section 50C can be considered as the full value of consideration'. The Learned JCIT(Appeals) erred in law in effectively importing a notional figure derived from a private engineer's estimate for enhancement. Section 50C does

DCIT Circle-14(2), New Delhi vs. Meenu Shukla, Noida

In the result, the appeal of the Revenue is dismissed

ITA 175/DEL/2020[2015-16]Status: DisposedITAT Delhi17 Dec 2025AY 2015-16

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2015-16] Deputy Commissioner Of Ms. Meenu Shukla, Income Tax, Circle-14(2), C-35, Sector-30, Room No.323, Cr Building, Vs Gautam Budh Nagar, Noida, I.P. Estate, New Delhi-110002 Uttar Pradesh-201301 Pan-Afyps8002B Appellant Respondent Assessee By Shri Ruchesh Sinha, Adv. Ms. Monalisha Maity, Adv. Revenue By Ms. Monika Singh, Cit-Dr Date Of Hearing 28.10.2025 Date Of Pronouncement 17.12.2025

Section 143(3)Section 2(47)Section 50CSection 54

under consideration, the assessee has sold her residential property at Sector-31, Noida resulting into capital gain of Rs.2,42,65,406/- (taking full value of consideration as per section 50C of the Act at Rs.2,77,24,000/-, against the indexed cost of acquisition of Rs.34

ITO Ward - 18(3), New Delhi vs. Samkiksha Mahajan, New Delhi

ITA 347/DEL/2021[2005-06]Status: DisposedITAT Delhi16 Dec 2025AY 2005-06

Bench: Shri Mahavir Singh, Hon’Ble & Shri Krinwant Sahay, Hon’Ble

For Appellant: Sh. Salil Kapoor, Ms. Ananya KapoorFor Respondent: Ms. Monika Singh, CIT(DR)

Section 132Section 133(6)Section 139Section 153A

notification dated 30.05.2005 (Para 3.3, Page 10 of the appellate order). Section 50C of the Act is a Special Provision for calculating the full value of consideration in Certain cases. As per Section 50C, where consideration received as a result of transfer by an assessee of a Capital asset ... value adopted by Stamp Valuation Authority, then, the value so adopted for purpose of payment of Stamp Duty shall be deemed to be full value of consideration received as a result of such transfer. In the present case the Value adopted by Stamp Valuation Authority for the impugned property

Himmatbhai Madhabhai Patel, Ahmedabad vs. The ITO, Ward-5(3)(1), Ahmedabad

In the result, appeal of the assessee is allowed

ITA 1552/AHD/2025[2015-16]Status: HeardITAT Ahmedabad12 Dec 2025AY 2015-16

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyalhimmatbhai M. Patel, Vs. Ito, 18, Kailash Dham Part-2, Ward 5(3)(1), India Colony Road, Bapunagar, Ahmedabad Ahmedabad-380024 [Pan :Aanpd 2497 D] (Appellant) .. (Respondent) Assessee By : Shri S.N. Divetia & Shri Samir Vora, Ars Respondent By: Shri Kamal Deep Singh, Sr Dr Date Of Hearing 11.12.2025 Date Of Pronouncement 12.12.2025

For Appellant: Shri S.N. Divetia & Shri Samir Vora, ARsFor Respondent: Shri Kamal Deep Singh, Sr DR

Section 143(3)Section 250Section 263Section 56Section 56(2)(vii)

fifty thousand rupees, the aggregate fair market value of such property as exceeds such consideration… …… Section 50C reads as under:- Special provision for full value of consideration in certain cases. 50C. (1) Where the consideration received or accruing as a result of the transfer by an assessee of a capital ... adopted or assessed or assessable by the stamp valuation authority on the date of agreement may be taken for the purposes of computing full value of consideration for such transfer: Provided further that the first proviso shall apply only in a case where the amount of consideration, or a part