In the result, the appeal of the assessee is allowed
546/– prior to transfer were revalued to Rs.134,94,13,602/- without any corroborative evidence or documentation. The AO held that the assessee had adopted a colourable device by relying on an inflated and unsubstantiated valuation to determine the consideration at Rs. 110.03 crore. 10. The AO also observed that neither the assessee nor the valuer had furnished concrete evidence