Commissioner passed the Revision order on the ground that  the valuation as per stamp valuation is more than the actual consideration paid by the assessee. Tribunal set aside the order of the Commissioner on the ground that  no presumption could be drawn on the ground that  purchaser of property must have paid more than what was actually recorded in account books. On appeal  dismissing the appeal of the Revenue the  Court held that it is not permissible to draw an inference from the circumstances surrounding a transaction  of sale of  property that the purchaser of the property must have paid more than what was actually recorded in his books of account. No presumption can be drawn on this aspect. Relied  on   Gayatri Enterprise v. ITO [2020]271 Taxman 276/420 ITR 15  (Guj)(HC)  (AY. 2012-13)