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2013 (4) TMI 42 - ITAT COCHINComputation of capital gain on sale of land - Valuation - CIT(A) adopted the average of four values and determined the value as on 01-04-1981 at Rs. 49,000/- per cent as against Rs. 15,000/- per cent determined by the AO - assessee submitted that the land sold by the assessee is located on the main road whereas the two lands referred by the Sub-Registrar are located on the side roads - Held that:- The land sold by the assessee is located on a main road called "Keston Road" and the lands referred by the Sub-Registrar are located in the side roads of Belhaven Gardens. Before the CIT(A), the assessee has filed valuation reports given by two different registered valuers and also the assessment record pertaining to Dr. Nirmala Devi Ravindran who had also sold a property located in that area. Hence, on a conspectus of the matter, the CIT(A) has determined the value as on 01-04-1981 at Rs. 49,000/- by taking average of all available datas. Thus it can be fairly concluded that CIT(A) has taken a conscious decision after taking into consideration all the factors relating to the issue. AO has blindly placed reliance on the comparable cases collected from the Sub Registrar, without factoring in the price advantage commanded by the impugned property due to its strategic location. Thus no necessity to interfere with the decision taken by the CIT(A), as the principle of averaging generally evens out the abnormalities - against revenue.
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