A purchase contract is a promise in the future that ownership will be transferred to the rightful owner, while the deed of sale is the actual transfer of ownership to the buyer. 8. Ground 2 concerns the fair value determined by the AO pursuant to Paragraph 50C of the Law on income tax. During the valuation process, the AO invoked the provisions of Section 50C of the Act and assumed the full value of the value in accordance with the stamp duty assessment of Rs 3.16 crore for the valuation year 2011-12 and Rs 2,62,01,662 for the valuation year 2012-13. On appeal, the Ld. CIT(A) referred the valuation issue to DVO u/s 50C(2) of the Fair Value Act at the time of sale. The appraiser submitted the appraiser`s report in support of his assertion that the fair value of the property was much lower than the value assumed by the Stamp Duty Authority. However, the DVO determined the fair value of the property at the value assumed by the Stamp Duty Authority for the registration of sales titles. Therefore, Ld. CIT(A) confirmed the addition made by the AO to this account.
9. In front of us, the ld. The appraiser`s AR argued that the Sub-Registrar and the DVO considered the land to be for residential purposes and accordingly applied the rate of Rs. 2,000/- and 2300 per m² respectively. He argued that, according to Article 3 of the lease order issued by JDA, the land may only be used for agricultural buildings and not for other purposes. He also referred to Circular No. 3385 of 14.07.2014 and argued that the Government had clarified the application of the phrase DLC to agricultural land used for farm houses, but that the DVO rejected the applicability of that circular following the date of sale. Therefore, the ld. .
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