Held, that the Assessing Officer is  required to confront the material relied upon by him with the assessee before using it against the assessee. The contention of the assessee was that it was not aware that the stamp duty valuation was more than the sale consideration and the Assessing Officer did not confront the material with the assessee. The issue is restored to the Assessing Officer to confront the material that was relied upon by him to the assessee and after examining the reply given by the assessee, the Assessing Officer  may take appropriate decision in accordance with the law. (AY.2017-18, 2018-19)