“fair market value”

Capital GainsSection 55(2)Section 55(2)2,353 judgments

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

Leading authorities on fair market 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.

CIT v. ITC Ltd.

236 Taxmann 612 · 2016 · High Court

108

citing judgments

When computing deduction under Section 80IA, specifically for inter-unit transfer of power, the benefit cannot be claimed based on rates chargeable by distribution licensees to consumers. The deduction must be computed based on the rate fixed by the Tariff Regulation Commission for sale by electricity generating companies.

PCIT v. Chain House International (P) Ltd.

98 Taxmann.com 47 · 2018 · High Court

104

citing judgments

The Assessing Officer cannot arbitrarily reject a share valuation report prepared by an expert using recognized methods like NAV or DCF for the purpose of Section 56(2)(viib) without providing valid reasons to demonstrate its perversity or unreasonableness.

CIT v. Puja Prints

360 ITR 697 · 2014 · High Court

citing judgments

The amendment to Section 55A(a) of the Income-tax Act, 1961, which replaced "is less than" with "is at variance" as the condition for referring a valuation to a Departmental Valuation Officer, does not have retrospective effect. Consequently, for periods before July 1, 2012, a DVO reference is invalid if the declared value is not "less than" the fair market value.

Vodafone M-Pesa Ltd. v. PCIT

164 DTR 257 · 2018 · High Court

citing judgments

An assessee has the option to choose either the Discounted Cash Flow (DCF) method or the Net Asset Value (NAV) method for share valuation under Section 56(2)(viib) read with Rule 11UA. The Assessing Officer cannot substitute the chosen method or value without identifying a specific error in the assessee's valuation.

Hiaben Jayantilal Shah v. ITO

310 ITR 31 · 2009 · High Court

citing judgments

When an assessee presents a registered valuer's report for an asset, the Assessing Officer, if forming an opinion that the value claimed is less than the fair market value, must refer the valuation to the Valuation Officer under Section 55A(a). The AO cannot unilaterally reject the registered valuer's report or resort to Section 55A(b) in such a scenario.

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.

Judgments citing fair market value

Assistant Commissioner of Income Tax, Hyderabad vs. Mytrah Vayu (Gujarat) Private Limited, Hyderabad

In the result, the appeal ofthe Revenue is dismissed

ITA 172/AHD/2024[2015-16]Status: DisposedITAT Ahmedabad18 Dec 2024AY 2015-16

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinha

For Appellant: Shri P S Choudhary, CIT. DRFor Respondent: Date of Hearing

Section 56(2)Section 56(2)(viib)

respect of share premium collected by the assessee. The assessee had furnished a valuation report of the Chartered Accountant in support of fair market value (FMV) of the shares on the basis of discounted cash flow (‘DCF’) method of valuation. However, the AO rejected the valuation report furnished ... method or as per NAV method. The provisions of Rule 11UA(2)(b) of the Rules provides that the assessee can adopt the fair market value as per either DCF method or NAV method. The choice of method is that of the assessee.In the present case, the valuation was done

Deputy Commissioner of Income-Tax, Central Circle-1, Mangaluru vs. Sri. Suresh S Kanaji, Bengaluru

In the result, appeal of the revenue is hereby dismissed

ITA 483/BANG/2023[2018-19]Status: DisposedITAT Bangalore18 Dec 2024AY 2018-19

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri H Shiva Prasad Reddy, IRSFor Respondent: Shri Sridhar E, CIT (DR)

Section 143(1)Section 153CSection 195

copy of the market price of the property from the Sub-Registrar authority, which supports the consideration of ₹1.46 crore as the fair market value of the property. The AO has not contradicted or disproved this evidence. 15.4 The vendors have independently confirmed the sale of the property

Narayan Das Talreja, N.S.M., Azadpur, Delhi vs. ITO Ward 36(1), New Delhi

In the result, appeal of the assessee is partly allowed

ITA 2564/DEL/2023[2018-2019]Status: DisposedITAT Delhi18 Dec 2024AY 2018-2019

Bench: Shri Vikas Awasthyआअसं.2564/िद"ी/2023(िन.व. 2018-19) Narain Dass Talreja, (Through Kishore Talreja Lr) B-206, New Subzi Mandi, Azad Pur, Delhi-110033 ...... अपीलाथ"/Appellant Pan: Acspt-4460-B बनाम Vs. Income Tax Officer, Income Tax Department, ..... "ितवादी/Respondent National E-Assessment Centre, Delhi अपीलाथ" "ारा/ Appellant By : S/Shri K.P Ganguly & Narender Kumar, Advocate "ितवादी"ारा/Respondent By : Shri Sanjay Tripathi, Sr. Dr सुनवाई क" ितिथ/ Date Of Hearing : 19/09/2024 घोषणा क" ितिथ/ Date Of Pronouncement : : 18/12/2024 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Order Of Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi (Hereinafter Referred To As 'The Cit(A)') Dated 19.07.2023, For Assessment Year 2018-19. 2. The Facts Of The Case In Brief As Emanating From Records Are: The Assessee Is A Commission Agent & Is Engaged In Trading Of Fresh Fruits. The Assessee Filed Its Return Of Income For The Impugned Assessment Year Declaring Income Of Rs.9,30,120/-. In The Course Of Assessment Proceedings The Assessing Officer (Ao) Found That In Violation Of Provisions Of U/S. 40A(3) Of The Income Tax Act, 1961(Hereinafter Referred To As ‘The Act’) The Assessee Has Made Payment In Cash In Excess Of Rs.10,000/- To A Single Person & There Are Several Such Payments. Hence, He Made Disallowance U/S. 40A(3) Of The Act On Following Transactions:

For Appellant: S/Shri K.P Ganguly, & Narender Kumar, AdvocateFor Respondent: Shri Sanjay Tripathi, Sr. DR

Section 40A(2)Section 40A(3)

made by the AO, where in his opinion excessive or unreasonable payments having with regard to fair market value of goods, services or facilities is made to the relative of the assessee, if assessee is an individual. A bare perusal of assessment order and impugned order reveals that the authorities ... below have not determined the fair market value of goods/services. The disallowance has been made merely on the basis of comparative commission payments made by the assessee to his son and his brother. As per section 2(41) of the Act, brother and son both fall within the definition

Mallesh Manthri, Hyderabad vs. ITO., Ward-15(1), Hyderabad

In the result, appeal filed by the assessee is allowed

ITA 362/HYD/2024[2014-15]Status: DisposedITAT Hyderabad17 Dec 2024AY 2014-15

Bench: Shri Manjunatha G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.362 /Hyd/2024 (निर्धारण वर्ा/Assessment Year: 2014-15) Mallesh Manthri Vs. Income Tax Officer Hyderabad Ward-15(1) [Pan :Akdpm3296M] Hyderabad (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Mohd.Afzal, Ar रधजस् व द्वधरध/Revenue By:: Shri R.Kumaran, Dr सुिवधई की तधरीख/Date Of Hearing: 17/12/2024 घोर्णध की तधरीख/Date Of 17/12/2024 Pronouncement: आदेश / Order Per. Manjunatha G., A.M: This Appeal Filed By The Assessee Is Directed Against The Order Dated 13.02.2024 Of The Learned Commissioner Of Income Tax (Appeals) [Ld.Cit(A)], National Faceless Appeal Centre, Delhi, Pertaining To A.Y.2014-15 On The Following Grounds : 1. The Order Of The Learned Commissioner Of Income Tax (Appeals) Is Against The Law, Weight Of Evidence & Probabilities Of Case. 2. The Learned Commissioner Erred In Confirming An Addition Of Rs.95,54,666/-, Which Was Made By Invoking The Provisions Of Section 56(2)(Vii)(B) Of The It Act.

For Appellant: Mohd.Afzal, ARFor Respondent: : Shri R.Kumaran, DR

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

purchased nor sold any 4 property and thus the question of paying consideration as stated by the Assessing Officer and the difference in fair market value of the property as on the date of registration does not arise and therefore, the question of invoking the provisions of section ... present case, the assessee neither purchased the property as claimed by the Assessing Officer, nor paid any consideration, which is less than the fair market value of the property, therefore, in our considered view, the provisions of section 56(2)(vii)(b) cannot be pressed into service. The Assessing Officer

Shaha Finlease Private Limited, Mumbai vs. Dy Commissioner of Income Tax 13(2)(2), Mumbai

In the result, appeal of the assessee is allowed

ITA 4182/MUM/2023[2013-14]Status: DisposedITAT Mumbai17 Dec 2024AY 2013-14

Bench: SHRI AMIT SHUKLA (Judicial Member), MS PADMAVATHY S (Accountant Member)

Section 143(3)Section 56Section 56(1)(viib)Section 68

then suomoto applied Net Asset Value (NAV) method invoking Explanation (a)(2) below Section 56(1)(viib) and determined the fair market value and the share @Rs.3.07. Thus, he applied one of the method under Rule 11UA and concluded that assessee received share premium of Rs.46.93/- per share which comes ... commercial prudence of such big investors like. According to the Assessing Officer either these investors should not have made investments because the fair market value of the share is Nil or assessee should have further invested in securities earning interest or dividend. …… 13. From the aforesaid extract of the impugned

The ACIT, Circle-2(1)(1), Ahmedabad vs. Mayora India Private Limited (Formerly Known As, Ahmedabad

In the result, the appeals of the Department are dismissed

ITA 419/AHD/2023[2018-19]Status: DisposedITAT Ahmedabad16 Dec 2024AY 2018-19

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Tushar Hemani, Sr. Adv. & ShriFor Respondent: Shri R. N. Dsouza, CIT D.R

Section 68

Surat Bench of ITAT reported in [2022] 138 taxmann.com 560 (Sutat-Trib). Further, even if the consideration received for shares exceeds the fair market value, the same is not liable to be added as income/of the company, if the amount is received from a nonresident. In the present case even

The ACIT, Circle-2(1)(1), Ahmedabad vs. Mayora India Private Limited (Formerly Known As "Inbisco India Pvt. Ltd.), Ahmedabad

In the result, the appeals of the Department are dismissed

ITA 418/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad16 Dec 2024AY 2017-18

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Tushar Hemani, Sr. Adv. & ShriFor Respondent: Shri R. N. Dsouza, CIT D.R

Section 68

DCIT, Circle-1(1), Hyderabad vs. Prakash Nimmagadda, Hyderabad, Secunderabad

In the result, appeal filed by the Revenue is dismissed

ITA 974/HYD/2017[2008-09]Status: DisposedITAT Hyderabad16 Dec 2024AY 2008-09

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita No.974/Hyd/2017 (िनधा"रण वष"/Assessment Year: 2008-09) Dy.Cit Vs. Shri Prakash Nimmagadda Circle 1(1) Hyderabad Hyderabad Pan:Acbpn4246R (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri K.C. Devdas, Ca राज" व "ारा/Revenue By:: Dr. Meghnath Chowhan, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 06/11/2024 घोषणा की तारीख/Pronouncement: 16/12/2024 आदेश/Order Per Vijay Pal Raothis Appeal Filed By The Revenue Is Directed Against The Order, Dated 20/03/2017 Of The Learned Cit (A)-9, Hyderabad, Relating To A.Y.2008-09. 2. The Revenue Has Raised The Following Grounds:

For Appellant: Shri K.C. Devdas, CAFor Respondent: : Dr. Meghnath Chowhan, CIT(DR)

Section 17(2)(c)Section 28

assessee and allotment of shares at a face value which resulted a non-monetary benefit to the assessee in comparison to the fair market value of the shares at which allotted to 3rd person and the said benefit is an income of the assessee ... Supreme Court in case of Excel Industries. 14. Any perquisite to be taxed, there shall be valuation rules to define the Fair Market Value, Cost etc. If no rules are prescribed, the computation fails and hence taxation of perquisite is not possible as held by the Hon'ble Supreme Court

Urvi Premal Shah, Bandra-East vs. ITO, Ward-19(3)(1), Tardeo Road

In the result, the assessee’s appeal is allowed

ITA 170/MUM/2024[2018-19]Status: DisposedITAT Mumbai16 Dec 2024AY 2018-19

Bench: SHRI BR BASKARAN (Accountant Member), SHRI SUNIL KUMAR SINGH (Judicial Member)

Section 143(2)Section 149(1)(ii)Section 250Section 56(2)(X)Section 68

learned CIT(A) has erred in upholding the assessment order, confirming the addition of Rs. 5,03,18,734/-, being difference between the ‘fair market value’ of equity shares gifted from relative and the cost of acquisition by previous owner/donor by invoking section ... whether the difference in the cost of shares donated by the assessee’s relative to assessee and that recorded at ‘fair market value’ by the assessee, be treated as unexplained credit u/s 68 of the Act? 6. Learned representative for the assessee has submitted that the shares gifted

ACIT 14(1)(2), Mumbai vs. Bombay Footwear Private Limited, Mumbai

Accordingly, all the Grounds raised by the Revenue are dismissed

ITA 94/MUM/2024[2017-18]Status: DisposedITAT Mumbai12 Dec 2024AY 2017-18

Bench: SHRI NARENDRA KUMAR BILLAIYA, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Ms. Aarti Vissanji and Shri Ajay BhandariFor Respondent: Dr. Mahesh Akhade

Section 143(3)Section 250Section 263Section 270ASection 45Section 50D

assessee is not ascertainable or cannot be determined, then, for the purpose of computing income chargeable to tax as capital gains, the fair market value of the said asset on the date of transfer shall be deemed to be the full value of the consideration received or accruing ... Lakhs Ninety Two Thousand only) on which stamp duty has been paid at the time of registration of the agreement as the fair market value of the said asset on the date of transfer as the full value of the consideration received as a result of the transfer

Astt. Commissioner of Income Tax, Lucknow vs. M/S Prag Industries (India) Pvt. Ltd., Lucknow

In the result, appeal of Revenue and Cross Objection of assessee, both are dismissed

ITA 660/LKW/2016[2013-14]Status: DisposedITAT Lucknow11 Dec 2024AY 2013-14

Bench: Shri Kul Bharat, Videshri Anadee Nath Misshra

Section 40A(2)

specified u/s 40A(2)(b) of the I. T. Act and secondly; if the expenditure is excessive or unreasonable having regard to the fair market value of the goods, services or facilities for which the payment is made or the legitimate needs of the business or the profession ... Rakesh Jain (HUF) who being a specific person u/s 40A(2)(b) of the Act; is excessive or unreasonable having regard to the fair market value of the goods, services or facilities for which the payment is made or the legitimate needs of the business or the profession

Rita Goel, Banglore vs. Assistant Commissioner of Income Tax Circle 4(2)(1), Bangalore, Bengaluru

In the result, appeal of the assessee is allowed

ITA 1230/BANG/2024[2017-18]Status: DisposedITAT Bangalore11 Dec 2024AY 2017-18

Bench: Shri Waseem Ahmed & Shri Prakash Chand Yadavassessment Year: 2017-18

For Appellant: Ms. Hema Sharma, A.RFor Respondent: Sri Subramanian S., D.R

Section 143(3)Section 50CSection 54Section 54FSection 55A

matter to the DVO and the ld. DVO determined the cost of acquisition as on 1.4.1992 @ Rs.92,02,400/- and hence, discarded the fair market value disclosed by the assessee. The AO thereafter taxed the difference in the hands of assessee and restricted the claim

Niket Ravibhai Patel, Vadodara vs. The Dy.CIT, Circle-1(1)(1), Vadodara

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

ITA 1215/AHD/2024[2013-14]Status: DisposedITAT Ahmedabad10 Dec 2024AY 2013-14

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Makarnad Vasant Mahadeokar (Accountant Member)

Section 143(3)Section 50C

case of assessee whose share is 5% in the above properties. Further Ld. Counsel relied upon decisions of the Tribunal when Fair Market Value of land determined by DVO was within 10% of purchase price, showing no significant difference from purchase consideration, no addition under section ... consideration all relevant material gathered by the undersigned, I.T.A No. 1215/Ahd/2024 A.Y. 2013-14 Page No 5 Niket Ravibhai Patel vs. DCIT the Fair Market Value of the property as under is considered just fair and reasonable. Sr. Property address and location Date of Declared value Assessed No. Valuation

Indus Towers Limited (Formerly Known As Bharti Infratel Ltd and As Successor in Interest of Erstwhile Indus Tower Ltd), Gurugram, Haryana vs. DCIT, Circle 12(1), New Delhi

In the result, the appeal of the revenue is dismissed

ITA 2762/DEL/2023[2010-11]Status: DisposedITAT Delhi10 Dec 2024AY 2010-11

Bench: Shri M. Balaganesh & Shri Vimal Kumarindus Towers Ltd (Formerly Vs. Dcit, Known As Bharti Infratel Ltd), Circle-12(1), 4Th Floor, Dlf Cybercity, New Delhi Building No. 10, Tower A, Dlf Qe, So Gurgaon, Haryana (Appellant) (Respondent) Pan: Aadcv0274F Acit, Vs. Indus Towers Ltd, 4Th Floor, Dlf Cybercity, Central Circle-10, New Delhi Gurgaon, Haryana (Appellant) (Respondent) Pan: Aadcv0274F Indus Towers Ltd (Formerly Vs. Dcit, Known As Bharti Infratel Ltd), Circle-12(1), 4Th Floor, Dlf Cybercity, New Delhi Building No. 10, Tower A, Dlf Qe, So Gurgaon, Haryana (Appellant) (Respondent) Pan: Aadcv0274F Assessee By : Shri Ajay Vohra, Sr. Adv Shri Rohit Jain, Adv Shri Deepesh Jain, Adv Ms. Shaurya Jain, Ca Revenue By: Shri Mukesh Kumar Jain, Cit Dr Date Of Hearing 12/09/2024 Date Of Pronouncement 10/12/2024

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Mukesh Kumar Jain, CIT DR

Section 115JSection 139(5)Section 142Section 143(3)Section 148

demerger scheme. The issue that was before the Hon‟ble Madras High Court was whether depreciation is eligible to that assessee on the fair market value of assets. The brief facts of that case are Ponni Sugars and Chemicals Ltd (PSCL) set up Erode Sugar Mill in Tamil Nadu ... said scheme contemplated a slump sale u/s 2(42C) of the Act wherein transfer of assets of Erode Unit was made on fair market value to the transferee company and transferee company claimed depreciation on the basis of fair market value of assets in the return of income. The learned

ACIT, Circle 10, New Delhi vs. Indus Tower Limited, Gurgaon

In the result, the appeal of the revenue is dismissed

ITA 2212/DEL/2023[2010-11]Status: DisposedITAT Delhi10 Dec 2024AY 2010-11

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Mukesh Kumar Jain, CIT DR

Section 115JSection 139(5)Section 142Section 143(3)Section 148

Indus Towers Ltd., Gurgaon vs. DCIT Circle 12(1), New Delhi

In the result, the appeal of the revenue is dismissed

ITA 1962/DEL/2023[2010-11]Status: DisposedITAT Delhi10 Dec 2024AY 2010-11

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Mukesh Kumar Jain, CIT DR

Section 115JSection 139(5)Section 142Section 143(3)Section 148

DCIT, Central Circle 1(1) Ahmedabad, Ahmedabad vs. Navratna Organisers and Developers Private Limited, Ahmedabad

In the result the appeal filed by the Revenue is hereby dismissed

ITA 895/AHD/2024[2007-08]Status: DisposedITAT Ahmedabad06 Dec 2024AY 2007-08

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 143(3)

submitted transfer agreement executed with purchaser party. Merely by not submitting such agreement, the AO cannot replace the actual sale value with estimated fair market value as same is contrary to provisions of the Act as were existing in A.Y.2007-08. It is observed that the AO has not brought

Vaishnav Yashwant Ashtankar, Nagpur vs. The Principal Commissioner of Income Tax - Nagpur 2, Nagpur

In the result, appeal filed by the assessee is allowed

ITA 240/NAG/2024[2016-2017]Status: DisposedITAT Nagpur06 Dec 2024AY 2016-2017

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Manoj G. MoryaniFor Respondent: Shri Sandipkumar Salunke

Section 142(1)Section 144BSection 147Section 148Section 263Section 44ASection 56(2)Section 56(2)(vii)

following details: a. Source of investment along with supporting documentary evidence. b. Copy of the deed of registration of the property. c. Fair market value of the property determined by the competent authority as on the date of purchase. d. Cash flow statement for the year e. Copy of cash

Yashwant Pandurangji Ashtankar, Nagpur vs. The Principal Commissioner of Income Tax - Nagpur - 2, Nagpur

In the result, appeal filed by the assessee is allowed

ITA 236/NAG/2024[2016-2017]Status: DisposedITAT Nagpur06 Dec 2024AY 2016-2017

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Manoj G. MoryaniFor Respondent: Shri Sandipkumar Salunke

Section 142(1)Section 144BSection 147Section 148Section 263Section 56(2)(vii)Section 69

Pandurangji Ashtankar sec.56(2)(vii)(b), you have liable to pay taxes on the difference amount between the actual sale consideration and the fair market value. Please furnish the copy of challan of taxes paid, if any. 5. Please furnish the copy of purchase deed of the said property

Tejas C. Joshi, Ahmedabad vs. The Dy.CIT, Circle-5(3)(Original Jurisdiction) the Dy. CIT, Cent. Circle 2(2) (Present Jurisdiction), Ahmedabad

ITA 912/AHD/2023[2015-16]Status: DisposedITAT Ahmedabad05 Dec 2024AY 2015-16

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. No. 912/Ahd/2023 ("नधा"रण वष" / Assessment Year : 2015-16) बनाम/ Tejas C Joshi Dy. Commissioner Of 9A, Santosa Park Society, Income Tax Vs. Nr. Aadiraj Bunglow, Central Circle 5(3), Iskon Ambli Road, Thaltej, Ahmedabad (Original Ahmedabad - 380058 Jurisdiction) Dy. Commissioner Of Income Tax Central Circle 2(2), Ahmedabad (Present Jurisdiction) "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aanpj4735G (Appellant) .. (Respondent) अपीलाथ" ओर से /Appellant By : Shri Hardik Vora, A.R. ""यथ" क" ओर से/Respondent By : Shri Prasad Rao Waghe Annasaheb, Sr. Dr 22/11/2024 Date Of Hearing Date Of Pronouncement 05/12/2024

For Appellant: Shri Hardik Vora, A.RFor Respondent: Shri Prasad Rao Waghe Annasaheb

Section 56(2)(vii)

ground that the stamp duty ITA No. 912/Ahd/2023 [DCIT vs. Tejas C. Joshi] A.Y. 2015-16 - 4 – value was higher than the fair market value of the property. The AO, on the basis of the objection of the assessee, had referred the matter to the DVO. However, since the report