Held, that the value adopted by the stamp duty authority exceeded the value of the property on the date of transfer and the value so adopted was also not in dispute in any appeal, revision, or reference before any authority, court or the High Court. Even the Assessing Officer accepted that in the suit pending before the High Court, only the ownership of the land was in dispute and not the valuation of the land. Thus, when both the conditions of section 50C(2) of the Act were fulfilled, there was no basis in the findings of the Assessing Officer, which had been upheld by the Commissioner (Appeals).The issue is restored to the Assessing Officer for adjudication de novo after seeking a valuation report from the Valuation Officer in terms of section 50C of the Act.(AY.2015-16)