The Assessing Officer based on AIR information that the assessee has sold  a lease hold property  reopened the assessment as the assessee did not offer the capital gain. The AO assessed the entire sale consideration as per stamp valuation. CIT(A) affirmed the order of the AO. On appeal the Tribunal held that section 50C being a deeming provision is applicable only in respect of land or building or both and if capital asset under transfer cannot be described as land or building or both then section 50C will not apply.  Therefore   section 50C cannot be made applicable to leasehold rights in a land. (AY. 2011-12)