The Tribunal allowed the appeal, holding that Section 50C, which applies to the valuation of capital assets based on stamp duty for computing capital gains, does not apply when the asset has been converted to stock-in-trade. In this case, the assessee had converted a capital asset into stock-in-trade in 2008 and sold it in 2009. The Assessing Officer reopened the assessment under Section 147, applying Section 50C based on an internal audit objection, and taxed the difference between the sale price and stamp duty value. The Tribunal held that the reopening was invalid as it was based solely on an audit objection, which cannot be considered “information” under Section 147. Moreover, on merits, Section 50C could not be applied since the property sold was stock-in-trade, not a capital asset. (AY. 2009-10)