Assessee sold an immovable property for Rs. 5.50 crores. Registered valuer  valued the property at Rs. 5, 36,60,000.  In course of assessment proceedings, Assessing Officer referred case to DVO for determining fair market value (FMV) of property.  DVO determined FMV of property at Rs. 6.38 crores.  Assessing Officer, however, adopted value determined by Stamp Valuation Authority (SVA) at Rs. 8.38 crores as deemed sale consideration under section 50C  of the Act and added an amount of Rs. 2.98 crores as notional income.   Commissioner (Appeals) upheld order of Assessing Officer. On appeal the Tribunal held that  since difference in FMV as per actual sale consideration received by assessee and DVO was much lesser in comparison to difference in value as per Stamp Valuation Authority (SVA)  and DVO, deeming provisions of section 50C cannot be applied. (AY. 2015-16)