Dismissing the appeal of the Revenue, the Tribunal held that land or building or both referred to in S. 50C(1) do not include leasehold rights in land or building or both. Hence provision of S.50C is not applicable. On the facts an industrial plot of land was allotted by MIDC under a lease agreement to the assessee and subsequently assessee transferred the said leasehold land to SM Industries  for the remaining period of the lease in the year 2011 for a consideration of Rs. 2 crores. Therefor no addition could be made, assuming for a moment that transfer of a leasehold right in land is covered by S. 50C(1), the assessee is adequately safeguarded by first and second provisos to S. 50C as the stamp duty value of the said land at the relevant time was less than the actual consideration of Rs. 2 crores. (AY. 2017-18)