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49. (2026) 188 taxmann.com 1085 (Del Trib)
Consolidated Finvest and Holdings Ltd. v. DCIT
A.Y.: 2017-18 Date of Order: 24.07.2026
Sections: 50C, 142A, 153
Where, in making an addition under section 50C, the AO referred the property valuation to the DVO under the general provision of section 142A instead of the special provision of section 50C(2), no extension of the assessment time limit under Explanation 1(v) to section 153 was available.
FACTS
The assessee-company, an NBFC engaged in providing loans and making investments, filed its return for A.Y. 2017-18 and later a revised return declaring total income of Rs. 9,24,88,434. It sold a property at Nariman Point, Mumbai, for a sale consideration of Rs. 2,16,40,000, while stamp duty was paid on a circle rate of Rs. 2,85,80,744. The assessee contended that the Stamp Valuation Authority's value exceeded fair market value and placed on record an independent Government valuer's report valuing the property at Rs. 2,13,28,000.
The AO referred the valuation to the Departmental Valuation Officer (DVO) on 11.11.2019, a fact never intimated to the ass
