s. 50C – Circle-rate prevailing on the date of execution of sale deed is relevant & not the rate on registration date

Assessee sold the land vide registered agreement dated 27th May 2004, for consideration of Rs.2,62,08,000/- and on the said date the circle rate was Rs.13,000/- per sq meter. However, on the date of registration of sale-deed, i.e. 16th September 2004, the circle-rate enhanced to Rs.20,000/- per sq meter. It was thus prayed that the AO was not justified to enhance the sale consideration, on the basis of circle-rate prevailing on the date of execution of sale deed. The ld CIT(A) however rejected the said submission and held that u/s 50C of the Act, the circle-rate has to be adopted on the date o...