This compilation indexes twelve rulings pronounced by the Income Tax Appellate Tribunal (ITAT) across multiple benches — Hyderabad, Mumbai, Vizag, Raipur, Kolkata, Patna, Lucknow, Agra, and Dehradun — in which Section 50C(2) of the Income Tax Act, 1961 was among the sections engaged. The cases span assessment years ranging from 2010-11 to 2019-20 and were decided between January 2025 and September 2026. This index is intended for in-house tax teams, Big-4 associates, and law firm researchers who track ITAT activity on stamp-duty-based capital gains valuation disputes.

Research index only. This page summarises publicly available ITAT orders for legal research purposes. Nothing on this page constitutes legal advice, tax advice, or any form of professional opinion. Readers should consult the full text of each judgment and seek qualified advice before acting on any information herein.

The statutory framework in one paragraph

Section 50C of the Income Tax Act, 1961 provides a special deeming provision for computing capital gains on the transfer of a capital asset being land or a building or both: where the consideration received or accruing as a result of the transfer is less than the value adopted or assessed or assessable by a Stamp Valuation Authority (SVA) for the purpose of payment of stamp duty, the SVA value shall be deemed to be the full value of consideration for the purposes of Section 48. Section 50C(2), in particular, addresses situations where the assessee objects to the SVA's adopted value on the ground that it exceeds the fair market value of the property: in such cases, the Assessing Officer is required to make a reference to the Valuation Officer (VO) under Section 55A, and the value determined by the VO, or the SVA value if lower, is to be taken as the full value of consideration. This sub-section thus provides a statutory safeguard enabling assessees to seek an independent valuation where the stamp authority's value is disputed.

The 12 rulings

1. Rasala Kiran Kumar,Hyderabad vs ITO, Ward-10(1), Hyderabad

Bench: Income Tax Appellate Tribunal - Hyderabad
Date: 9 September 2026
Sections engaged: 144, 147, 148, 148A(b), 148A(d), 271D, 50C, 50C(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeals (ITA No.1464 & 1465/Hyd/2026) filed by the assessee for Assessment Year 2018-19 were directed against the orders of the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, dated 11/03/2026, which in turn arose from orders passed by the Assessing Officer under sections 147 read with 144 read with 144B of the Act, dated 28/12/2023, and also under section 271D of the Act. The source preview confirms reassessment and penalty proceedings were involved alongside the stamp valuation provisions.

2. Anant Govind Patil,Virar vs Income Tax, Thane

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 7 September 2026
Sections engaged: 144B, 147, 48, 50C, 50C(2), 55(2)(b)
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (ITA 2785/MUM/2026) was filed against the order of the NFAC, Delhi, dated 13.01.2026 for Assessment Year 2015-16. Per the source preview, the Assessing Officer applied section 50C of the Act, adopted Rs.1,58,68,750/- as the full value of consideration, and determined the assessee's proportionate share at Rs.11,33,482/- (being 1/14th thereof), in the absence of documentary evidence establishing a share different from that reflected in the conveyance deed.

3. Marri Usha,Usa vs ACIT, Int-Tax-1, Hyderabad

Bench: Income Tax Appellate Tribunal - Hyderabad
Date: 2 September 2026
Sections engaged: 292B, 50C(2), 56(2)(vii)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No.60/Hyd/2024) was filed by the assessee — a US-based non-resident individual — against the final assessment order for Assessment Year 2017-18, passed by the ACIT, International Taxation-1, Hyderabad. The source preview confirms the appeal was directed against a final assessment order; the substantive issues engaged included sections relating to stamp duty valuation and the deeming provisions applicable to property transactions.

4. Dy. Commissioner Of Income Tax vs Dhananjaya Rao Viswanadha

Bench: Income Tax Appellate Tribunal - Vizag
Date: 31 August 2026
Sections engaged: 48, 50C, 50C(1), 50C(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (ITA 454/Viz/2026) for Assessment Year 2016-17 was a Revenue appeal filed by the Deputy Commissioner of Income Tax, Circle-3(1), Visakhapatnam, against the assessee Dhananjaya Rao Viswanadha. The sections engaged — covering computation of capital gains and the stamp duty deeming provisions at both sub-section (1) and sub-section (2) level — indicate the core dispute concerned the appropriate full value of consideration to be adopted for the transfer of immovable property.

5. Sanjay Agrawal, Raipur,Raipur vs Income Tax Office, Ward-1(4), Raipur

Bench: Income Tax Appellate Tribunal - Raipur
Date: 31 August 2026
Sections engaged: 50C, 50C(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No.181/RPR/2026) arose from the order of the CIT(Appeals)/NFAC, Delhi, dated 17.12.2025 for Assessment Year 2013-14. At the time of hearing, no one appeared on behalf of the assessee; the Revenue was represented by a Senior DR. The appeal was filed against the CIT(A) order on the stamp valuation issue under sections 50C and 50C(2) of the Act.

6. Aries Export Private Limited,Mumbai vs Income Tax Officer, Mumbai

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 31 July 2026
Sections engaged: 50C(2), 56(2)(x)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA 4019/MUM/2026) was filed by the assessee against the order of NFAC, Delhi, passed under Section 250 of the Act for Assessment Year 2018-19, with the date of the NFAC order being 10.03.2026. The impugned order emanated from a National E-Assessment proceeding; the sections engaged indicate that both the stamp duty valuation provision and the deeming provision applicable to receipt of property without adequate consideration were in issue.

7. Maha Mai Developers & Co.,,Kolkata vs ITO, Ward 3(1),, Kolkata

Bench: Income Tax Appellate Tribunal - Kolkata
Date: 29 June 2026
Sections engaged: 155(15), 50C(2), 153
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (ITA No.559/KOL/2026) for AY 2018-19 was preferred by the assessee against the order of the National Faceless Appeal Centre, Delhi, dated 09.12.2025. Per the source preview, an additional ground was raised at the time of hearing, contending that an addition of Rs.1,06,74,034/- was wrongly made subject to rectification under section 155(15) on receipt of the District Valuation Officer's report, on the basis that the provisions of section 155(15) were not applicable to the facts of the case.

8. Abdush Salam,Sasaram vs Income Tax Officer, Delhi

Bench: Income Tax Appellate Tribunal - Patna
Date: 10 June 2026
Sections engaged: 50C, 50C(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (ITA No.181/PAT/2026) for Assessment Year 2018-19 was filed against the order of the NFAC, Delhi, dated 31.01.2026, passed under section 250 of the Act. Per the source preview, the assessee, an individual, had filed a return of income on 05.10.2018 declaring total income of Rs.19,31,990/-, and the case was selected for scrutiny on the issue of capital gains on the sale of immovable property — specifically the sale of 26.562 dismil of land — engaging the stamp duty valuation provisions.

9. Harjeet Singh Chhabra,Faizabad vs Income Tax Officer-I, Faizabad

Bench: Income Tax Appellate Tribunal - Lucknow
Date: 9 June 2026
Sections engaged: 56(2)(vii), 50C(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (I.T.A. No. 796/Lkw/2025) was filed by the assessee against the order of the CIT(A)/NFAC, Delhi, dated 30.06.2025 for Assessment Year 2014-15. The source preview notes that the appeal was filed beyond the prescribed time limit and an application for condonation of delay was filed; the Departmental Representative expressed no objection to the condonation of delay. The substantive issues engaged sections relating to stamp duty valuation and the deeming provision for receipt of property below fair market value.

10. Vijay Pal Singh,Hardoi vs Assessment Unit, NFAC

Bench: Income Tax Appellate Tribunal - Lucknow
Date: 30 March 2026
Sections engaged: 50C(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: In this case (I.T.A. No.56/LKW/2026) for Assessment Year 2019-20, the assessment order dated 21.03.2024 was passed by the Assessing Officer, whereby the assessee's total income was determined at Rs.1,99,26,867/- as against returned income of Rs.3,34,590/-. Per the source preview, an addition was made on account of Long Term capital gains, and documents including a copy of the sale deed, power of attorney, bank statements of co-owners, and an RTI reply dated 18/02/26 were placed on record.

11. Sanjana Gupta,Jhansi vs ITO-Ward-2(3)(1) Jhansi, Jhansi

Bench: Income Tax Appellate Tribunal - Agra
Date: 21 January 2026
Sections engaged: 50C(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 433/AGR/2025) for AY 2014-15 arose from the order of the JCIT(A), dated 27.03.2025, against an assessment order dated 15.12.2016. Per the source preview, there was a delay of 101 days in filing the appeal before the Tribunal, which was condoned in the interest of substantial justice; the sole effective issue before the Tribunal was whether the JCIT(A) was justified in confirming the addition made on account of differential consideration under the head "Capital Gains."

12. Akshat Bansal,Dehradun vs DCIT, Central Circle , Dehradun

Bench: Income Tax Appellate Tribunal - Dehradun
Date: 29 January 2025
Sections engaged: 153A(1)(b), 50C(2), 271(1)(c)
Outcome: Outcome not specified in source
Procedural / substantive ground: These four consolidated appeals (ITA Nos. 3944 & 3945/Del/2016 for AYs 2011-12 & 2012-13, and ITA Nos. 115 & 116/DDN/2016 for AYs 2010-11 & 2012-13) arose against orders of the CIT(A), Muzaffarnagar, dated 30.03.2016, and the CIT(A)-IV, Kanpur, both dated 22.05.2019, involving proceedings under section 153A(1)(b) of the Act. The appeal was heard via video conferencing; the assessee was unrepresented, and the Department was represented by a Senior DR.

Patterns across these 12 rulings

Consistent NFAC routing. Across the majority of cases in this compilation, the first appellate stage was the National Faceless Appeal Centre (NFAC), Delhi — reflecting the widespread implementation of faceless appeals as a structural feature of the litigation pipeline for Section 50C(2) disputes.
AY 2018-19 recurrence. Multiple cases in this set — including cases 1, 6, 7, and 8 — share Assessment Year 2018-19, suggesting that disputes arising from transactions in that year involving stamp duty valuation have matured to the ITAT stage during 2025-2026.
Companion sections alongside 50C(2). Section 50C(2) does not appear in isolation in most of these appeals: it is frequently accompanied by other provisions — including section 56(2)(vii) (cases 3 and 9), section 56(2)(x) (case 6), section 48 (cases 2 and 4), and section 271(1)(c) (case 12) — indicating that stamp valuation disputes often generate parallel issues around deemed income on the buyer's side or concealment penalties.
Revenue as appellant in at least one instance. Case 4 (Dy. Commissioner of Income Tax vs. Dhananjaya Rao Viswanadha, ITAT Vizag) is a Revenue appeal, as distinct from the remaining cases which are assessee appeals — demonstrating that the Department also challenges CIT(A) orders that grant relief on Section 50C valuation grounds.
Procedural delays and condonation. At least two cases (cases 9 and 11) explicitly note delays in filing the ITAT appeal, with condonation sought and granted or not objected to — a recurring procedural feature in Section 50C litigation where taxpayers may face compressed timelines following NFAC orders.

How to use this compilation

This index functions as a first-pass research tool. Each case entry provides the identity fields (bench, date, sections, ITA number, and assessment year where available from the source preview) sufficient to locate the full order on indiankanoon.org, the official ITAT e-filing portal, or the relevant court website. Researchers should treat the "Procedural / substantive ground" entries as orientation notes drawn from publicly available text previews — not as summaries of the full reasoning or operative holdings of the orders, which are not reproduced here in their entirety.

Before relying on any ruling listed above, verify the following: (a) that the full order has not subsequently been stayed, reversed, or modified by a High Court or the Supreme Court in further proceedings; (b) that no rectification application, review petition, or miscellaneous application has altered the final operative direction; and (c) that any CBDT circular, instruction, or notification issued after the date of the order has not changed the applicable legal framework, particularly with respect to the tolerance limit under Section 50C(2) as may be amended from time to time.

Researchers working across multiple benches should be aware that ITAT decisions are not binding precedents across benches in the way High Court decisions are — a ruling from ITAT Hyderabad does not bind ITAT Lucknow. Where conflicting views exist across benches on the application of Section 50C(2), the jurisdictional High Court's position, or in its absence the Special Bench or a larger coordinate bench ruling, should be identified and applied. Always cross-check cited judgments listed in the source preview of any order (such as those referenced in case 10) for their current precedential status.

Source

All cases listed above are drawn from the TaxNoticeAI structured legal corpus (16,101 Indian tax judgments, CBIC circulars, ITAT rulings, AAR rulings, GSTAT rulings), sourced from indiankanoon.org and official court portals.

Section 50C(2) Capital Gains: 12 ITAT Rulings on Stamp Duty Valuation Disputes (2025–2026)