The assessee purchased a piece of land. Assessment was completed .  Subsequently the order was set aside in revision and an addition was made to his income under S. 69 on the ground that there was a difference between the value of the land shown in the sale deed and the stamp value. The order of revision was upheld by the Tribunal. On appeal , High Court held that there was nothing on record to indicate what was the price of the land at the relevant time. Even otherwise, it was a pure question of fact. Apart from the fact that the price of the land was different from that recited in the sale deed unless it was established on record by the Department that as a matter of fact, the consideration as alleged by the Department did pass to the seller from the purchaser, it could not be said that the Department had any right to make any additions. The addition was not justified. (R/TA. No 399 of 2019 dt 20 -08 2019 )    (AY. 2011-12)