In case of a transfer of capital asset, what can be taxed in the hands of the seller is real or actual gain that accrues/ arises from transfer of the assets and hence, in absence of any sale consideration no notional gain can be imputed in the hands of the seller to tax such transfer. The AO has failed to understand that carrying out revaluation and passing accounting entry in the books of account does not represent transfer taken by the assessee. Further, provisions of section 50D which provides for fail market value deemed to be the full value of consideration in certain cases has been inserted by the Finance Act, 2012 . for the assessment year 2013 -14  and hence cannot be applied for the year under consideration i.e. AY. 2010-11. (AY. 2010-11)