S.50C is applicable only in case of “Seller” and not in case of “Buyer”:

AO made addition u/s 69B on the basis of difference in valuation of land. On appeal, both, CIT(A) and the Hon’ble ITAT, deleted the said addition after holding that provisions of S.50C will apply to “Seller” only and not to a “Purchaser”.On Revenue’s appeal, the Hon’ble High Court held that S.50C, by a deeming fiction, substitutes the consideration received on sale of a capital asset by stamp duty valuation. Such deeming fiction, however, is applicable only in case of a “Seller” for the purpose of S.48. Hence, ITAT had committed no error in confirming the view taken by CIT(A). Accordingly, Revenue’s tax appeal was dismissed.

[SARJAN REALITIES LTD. - TAX APPEAL NO.1374 of 2011 - GHC]