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In favour of assessee.We are inclined to quash the impugned order on the ground that there could not have been any presumption for the purpose of making addition under Section 69B of the Act.

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Section 50C and 69 of the Income Tax Act, 1961 — Capital gains — Unexplained Investments — The provisions of section 50C cannot be applied for the purpose of making an addition under section 69. There was nothing on record to indicate what was the price of the land at the relevant time even otherwise,  it was a pure question of fact and apart from the fact that the price of the land was different from that recited in the sale deed unless it was established on record by the Department that as a matter of fact, the consideration as alleged by the Department did pass to the seller from the purchaser. it could not be said that the Department had any right to make any additions, the addition was not justified — Gayatri Enterprises vs. Income tax Officer [2020] 420 ITR 15 (Gujarat)

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