# ITAT Mumbai: Higher stamp value alone cannot prove undisclosed income

2026-08-13T11:44:16+00:00 | Governance | Indian Opinion Desk

Corroboration: 1 independent outlet

The Income Tax Appellate Tribunal (ITAT) Mumbai has ruled that a higher stamp-duty valuation of a property, by itself, cannot prove that a buyer made an undisclosed investment. The order came in the case of a Pune property buyer who paid Rs 6.5 crore for a property valued at Rs 8.85 crore for stamp duty purposes. The tax department had added Rs 2.35 crore as unexplained investment under Section 69B of the Income-tax Act, based solely on the difference. The tribunal held that the Revenue must produce independent evidence of extra payment to invoke Section 69B. It also distinguished Section 50C, which deems stamp value as consideration for a seller, saying that fiction cannot apply to a buyer. The relief stands after the Commissioner of Income Tax (Appeals) had earlier deleted the addition.

## Coverage

- livemint.com <https://www.livemint.com/money/personal-finance/property-bought-for-6-5-crore-but-valued-at-8-85-crore-how-buyer-won-relief-from-2-35-crore-tax-addition-11786602401216.html>
- livemint.com <https://www.livemint.com/money/personal-finance/deposited-over-50-lakh-cash-in-bank-account-no-itr-filed-heres-why-itat-ruled-in-taxpayers-favour-11786622947034.html>

Tags: Income tax, ITAT, property tax, Section 69B, stamp duty
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