During assessment year 2017-18, assessee-trust sold immovable property for consideration of Rs. 52.52 crores which was duly offered to tax.  Sale deed was registered on 17.05.2017 (relevant to Assessment Year 2018-19).  Subsequently, return of income for relevant year 2018-19 was filed by assessee declaring income at Rs. NIL which was accepted and assessment order was passed.  Commissioner invoked revision for relevant year 2018-19 on ground that stamp duty value of immovable property sold by assessee was Rs. 82.31 crores as per provisions of section 50C, and therefore, difference between stamp duty value and transaction value was not examined by Assessing Officer which made his order erroneous so far as prejudicial to interest of revenue. On appeal the Tribunal held that the  assessee had offered capital gain in assessment year 2017-18,  property was transferred in that year, property got registered in current assessment year, thus, capital gain offered by assessee had been assessed to income tax in assessment year 2017-18. Further there is no provision under section 11(1A) to substitute net consideration with full value of deemed consideration. Even otherwise in case of assessee, a trust, according to provisions of section 11(1A) where a capital asset was sold, transferred, net consideration was required to be utilized for acquisition of another capital asset and in those circumstances, net consideration was deemed to have been applied for charitable purposes to extent consideration was utilized.Therefore  order under section 263 passed by CIT for relevant year is  unjustified. (AY. 2017-18)