Sec. 50C of the Income-tax Act, 1961 - Capital gain - The attempt on the part of the AO to make the addition with the aid of the statement of the partner of the assessee and reference to the correct stamp valuation, is simply invalid. What the AO wishes to do is to adopt a stamp valuation for the properties in question, superimpose the statement of the partner of the assessee of the declaration of certain additional income and extrapolate such statement to fit within the scheme of Section 43CA of the Act. Thus, the impugned notice of reopening of assessment is set aside. SLP of the revenue dismissed. - ITO V/s ZAIN CONSTRUCTIONS - [2020] 269 TAXMAN 274 (SC)