Mr. Ramu Subbiah, CHENNAI V. ACIT, CHENNAI

ITA 2058/CHNY/2016

• Counselvise Citation: [2016] 131 COUNSELVISE.COM (IT) 8443 (ITAT-CHENNAI)
• Duration Of Justice: 2 month(s) 17 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 23-09-2016
• Appeal Filed By: Assessee
• Order Result: Partly Allowed
• Bench Allotted: C
• Assessment Year: 2011-2012
• Appeal Filed On: 06-07-2016
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Department Lawyers: A V SREEKANTH
• Assessee Lawyers: S SRIDHAR
• Keywords: Sale consideration of property below Jantri Value; Capital asset; Fair market value
• Section: 50C

Judgement Text

, , IN THE INCOME TAX APPELLATE TRIBUNAL C BENCH, CHENNAI . . . , . !' , $ % BEFORE SHRI N.R.S. GANESAN, JUDICIAL MEMBER AND SHRI A. MOHAN ALANKAMONY, ACCOUNTANT MEMBER ./ ITA NO.2058/MDS/2016 ' (' / ASSESSMENT YEAR : 2011-12 SHRI RAMU SUBBIAH, C/O S. SRIDHAR, A.S. SRIRAMAN, ADVOCATES, NEW NO.14, OLD NO.82,FLAT NO.5, 1 ST AVENUE, INDIRA NAGAR, ADYAR, CHENNAI - 600 020. PAN : AELPR 7916 R V. THE ASSISTANT COMMISSIONER OF INCOME TAX, NON-CORPORATE CIRCLE 12, CHENNAI. (*+/ APPELLANT) (,-*+/ RESPONDENT) *+ . / / APPELLANT BY : SHRI S. SRIDHAR, ADVOCATE ,-*+ . / / RESPONDENT BY : SHRI A.V. SREEKANTH, JCIT 0 . 1$ / DATE OF HEARING : 29.08.2016 2!( . 1$ / DATE OF PRONOUNCEMENT : 23.09.2016 / O R D E R PER N.R.S. GANESAN, JUDICIAL MEMBER: THIS APPEAL OF THE ASSESSEE IS DIRECTED AGAINST THE ORDER OF THE COMMISSIONER OF INCOME TAX (APPEALS) -13, CHENN AI, DATED 19.05.2016 AND PERTAINS TO ASSESSMENT YEAR 2011-12. 2 I.T.A. NO.2058/MDS/16 2. SHRI S. SRIDHAR, THE LD.COUNSEL FOR THE ASSESSEE , SUBMITTED THAT THE ASSESSEE SOLD A PROPERTY TO M/S SURANA COR PORATION ON 25.03.2011 FOR A TOTAL CONSIDERATION OF ` 2,20,0,000/-. THE AREA OF THE LAND WAS 2.02 ACRES. SIMILARLY, THE ASSESSEE S OLD ANOTHER PROPERTY TO THE EXTENT OF 4.09 ACRES AT SHOLINGANAL LUR, TO M/S CHENNAI CYBERCITY (P) LTD. FOR A SUM OF ` 5,74,12,000/-. IN RESPECT OF SHOLINGANALLUR PROPERTY, THE ASSESSEE CLAIMED BE FORE THE ASSESSING OFFICER THAT THIS IS AN AGRICULTURAL LAND SUBJECTED TO CULTIVATION, THEREFORE, CANNOT BE CONSIDERED AS CAP ITAL GAIN. THE ASSESSING OFFICER FOUND THAT THE DISTANCE BETWEEN T HE SHOLINGANALLUR PROPERTY AND PERUMBAKKAM MUNICIPALIT Y WAS APPROXIMATELY 13.5 KMS. HOWEVER, THE ASSESSING AUT HORITY FOUND THAT THE POPULATION OF THE MUNICIPALITY WAS 15,519 AS PER CENSUS OF 2001. THE LD.COUNSEL FURTHER SUBMITTED THAT THE AS SESSEE HAS RETURNED AGRICULTURAL INCOME REGULARLY. IN FACT, F OR ASSESSMENT YEAR 2010-11, THE ASSESSEE HAS RETURNED A SUM OF ` 53,200/-. SIMILARLY FOR THE ASSESSMENT YEARS 2011-12 AND 2012-13, THE A SSESSEE HAS RETURNED AN AGRICULTURAL INCOME OF ` 53,200/- EACH. THIS CLAIM OF THE ASSESSEE WAS DISALLOWED ON THE GROUND THAT AGRICULT URAL INCOME DISCLOSED BY THE ASSESSEE WAS VERY LESS FOR A TOTAL AREA OF 6.11 ACRES. ACCORDING TO THE LD. COUNSEL, THE ASSESSEE HAS DISCLOSED 3 I.T.A. NO.2058/MDS/16 AGRICULTURAL INCOME EARNED FROM CULTIVATION. THERE FORE, MERELY BECAUSE THE AGRICULTURAL INCOME WAS VERY LESS, THE CLAIM OF THE ASSESSEE THAT THE PROPERTY WAS AGRICULTURE IN NATUR E CANNOT BE REJECTED. WHEN THE AGRICULTURAL INCOME DISCLOSED F OR EARLIER ASSESSMENT YEARS WAS ADMITTED, MERELY BECAUSE THE A SSESSEE WAS CLAIMING EXEMPTION FROM CAPITAL GAIN ON TRANSFER OF LAND, THE ASSESSING OFFICER CANNOT TURN AROUND AND SAY THAT T HE PROPERTY IS NOT AGRICULTURE IN NATURE. 3. REFERRING TO THE COPY OF PATTA AND ADANGAL, THE LD.COUNSEL FOR THE ASSESSEE SUBMITTED THAT THE STATE REVENUE D EPARTMENT CLASSIFIED THE LAND AS DRY LAND AND THE ASSESSEE WA S CULTIVATING THE SAME. THEREFORE, ACCORDING TO THE LD. COUNSEL, THE CIT(APPEALS) IS NOT JUSTIFIED IN CONFIRMING THE ORDER OF THE ASSESS ING OFFICER. 4. THE LD.COUNSEL FOR THE ASSESSEE FURTHER SUBMITTE D THAT THE ASSESSEE HAS SOLD THE LAND AS A SINGLE PIECE IN SHO LINGANALLUR VILLAGE. THE ASSESSEE ALSO SOLD ANOTHER LAND AT PE RUMBAKKAM VILLAGE. THE GUIDELINE VALUE ADOPTED BY THE SUB-RE GISTRAR IN SHOLINGANALLUR LAND WAS AT ` 5,74,12,000/-. IN RESPECT OF PERUMBAKKAM LAND, THE GUIDELINE VALUE ADOPTED BY TH E SUB- REGISTRAR WAS ` 2,20,18,000/-. BOTH SHOLINGANALLUR LAND AND 4 I.T.A. NO.2058/MDS/16 PERUMBAKKAM LAND ARE ONE PIECE OF PROPERTY. ACCORD ING TO THE LD. COUNSEL, THE ASSESSING OFFICER WITHOUT ANY JUSTIFIC ATION DIVIDED THE SAME INTO TWO PROPERTIES. EVEN THOUGH THE ASSESSEE EXECUTED TWO DIFFERENT SALE DEEDS AND THE PROPERTY FOUND IN TWO DIFFERENT VILLAGES, IT IS ONE PIECE OF LAND, THEREFORE, THERE CANNOT BE ANY TWO DIFFERENT GUIDELINE VALUE FOR THE PURPOSE OF VALUATION. ACCO RDING TO THE LD. COUNSEL, THERE CANNOT BE A HIGHER VALUE FOR ONE PAR T OF LAND AND LESSER VALUE FOR OTHER PART OF THE LAND. REFERRING TO DEPARTMENTAL VALUATION OFFICERS REPORT, THE LD.COUNSEL SUBMITTE D THAT THIS VALUATION WAS IN RESPECT OF 2400 SQ.FT. OF LAND, WH ICH IS OTHERWISE CONSIDERED TO BE ONE GROUND. WHAT WAS SOLD BY THE ASSESSEE IS 6.11 ACRES OF LAND. THE ENTIRE 6.11 ACRES OF LAND IS A SINGLE PIECE OF LAND. IN OTHER WORDS, WHAT WAS SOLD BY THE ASSESSE E IS 2,66,151 SQ.FT. OF LAND. THEREFORE, COMPARING A SMALL PIECE OF 2400 SQ.FT. OF LAND WITH LARGE JUNGLE OF 2,66,151 SQ.FT. OF LAND I S NOT JUSTIFIED. 5. THE LD.COUNSEL FOR THE ASSESSEE FURTHER SUBMITTE D THAT THE ASSESSEE CLAIMED BEFORE THE ASSESSING OFFICER AND A LSO BEFORE DEPARTMENTAL VALUATION OFFICER THAT THE LAND AT PER UMBAKKAM WAS TAKEN AT ` 250 PER SQ.FT. THE SHOLINGANALLUR VILLAGE IS NEXT TO PERUMBAKKAM VILLAGE AND THE LAND AT PERUMBAKKAM VIL LAGE IS 5 I.T.A. NO.2058/MDS/16 ADJACENT TO SHOLINGANALLUR LAND. THEREFORE, THERE IS NO JUSTIFICATION IN VALUING THE LAND AT PERUMBAKKAM AT ` 250/- PER SQ.FT. AND VALUING THE LAND WHICH FALLS IN SHOLINGANALLUR VILLAGE AT ` 750 PER SQ.FT. REFERRING TO COMPARABLE SALE INSTANCES, THE LD.COUN SEL SUBMITTED THAT A LAND OF 2.14 ACRES ADJACENT TO ASSESSEES LA ND, WAS SOLD FOR ` 2,14,00,000/- AT ` 100 LAKHS PER ACRE. THE ASSESSEE, IN FACT, GAVE A COPY OF REGISTERED SALE DEED TO THE DEPARTMENTAL VALUATION OFFICER. THE DEPARTMENTAL VALUATION OFFICER HOWEVE R, REJECTED THE COMPARABLE SALE INSTANCE SUGGESTED BY THE ASSESSEE ON THE GROUND THAT THE VALUE ADOPTED UNDER SECTION 47A OF THE STA MP ACT CANNOT BE MADE APPLICABLE TO THE ASSESSEE. ACCORDING TO T HE LD. COUNSEL, WHEN THE DOCUMENT WAS REFERRED TO COLLECTOR FOR DET ERMINATION OF MARKET VALUE AND THE MARKET RATE WAS ADOPTED UNDER SECTION 47A OF THE STAMP ACT, THE DEPARTMENTAL VALUATION OFFICE R CANNOT SAY THAT THE VALUE DETERMINED UNDER STAMP ACT CANNOT BE APPLIED TO THE ASSESSEE. ACCORDING TO THE LD. COUNSEL, THE VALUE DETERMINED BY THE COLLECTOR UNDER SECTION 47A OF STAMP ACT IS EQU ALLY APPLICABLE WHILE DETERMINING THE FAIR MARKET VALUE OF THE ASSE SSEES LAND. THEREFORE, ACCORDING TO THE LD. COUNSEL, THE VALUAT ION ADOPTED BY THE DEPARTMENTAL VALUATION OFFICER AT THE RATE OF ` 750/- PER SQ.FT. AT SHOLINGANALLUR VILLAGE IS NOT JUSTIFIED. 6 I.T.A. NO.2058/MDS/16 6. ON THE CONTRARY, SHRI A.V. SREEKANTH, THE LD. DE PARTMENTAL REPRESENTATIVE, SUBMITTED THAT THE ASSESSEE SOLD 2. 02 ACRES OF LAND ON 25.03.2011 FOR A SUM OF ` 2,20,00,000/- TO SURANA CORPORATION. THE FAIR MARKET VALUE WAS DETERMINED BY ADOPTING VA LUE DECLARED BY THE ASSESSEE AT ` 2,20,00,000/-. THE PROPERTY WAS SITUATED AT PERUMBAKKAM VILLAGE. ON THE SAME DAY, THE ASSESSEE ALSO EXECUTED ANOTHER DOCUMENT IN RESPECT OF PROPERTY AT SHOLINGANALLUR VILLAGE FOR A SALE CONSIDERATION OF ` 5,74,12,000/-. HOWEVER, THE REGISTRATION AUTHORITIES DETERMINED THE FAIR MARKET VALUE OF THE LAND AT SHOLINGANALLUR AT ` 13,37,43,000/-. ACCORDING TO THE LD. D.R., THE ASSESSEE CLAIMED BEFORE THE ASSESSING OFFICER THAT WHAT WAS SOLD BY THE ASSESSEE IS AGRICULTURAL LAND, THEREFORE, IT CANNOT BE A CAPITAL ASSET. THE ASSESSING OFFICER FOUND THAT THE DISTAN CE BETWEEN SHOLINGANALLUR PROPERTY AND PERUMBAKKAM MUNICIPALIT Y WAS APPROXIMATELY 13.5 KMS. HOWEVER, SHOLINGANALLUR HA D A POPULATION OF 15,519 AS ON 2001 CENSUS. THEREFORE, ACCORDING TO THE LD. D.R., THE ASSESSING OFFICER REJECTED THE CLAIM OF THE ASS ESSEE AND LEVIED CAPITAL GAIN TAX. 7. REFERRING TO THE CLAIM OF THE ASSESSEE THAT THE AGRICULTURAL INCOME WAS DISCLOSED IN THE EARLIER ASSESSMENT YEAR S, THE LD. D.R. 7 I.T.A. NO.2058/MDS/16 SUBMITTED THAT THE ASSESSEE HAS DISCLOSED ONLY A ME AGRE INCOME FROM AGRICULTURE. THEREFORE, THE ASSESSING OFFICER TREATED THE INCOME DISCLOSED AS AGRICULTURAL INCOME AS NON-AGRI CULTURAL INCOME AND BROUGHT THE SAME FOR TAXATION UNDER THE HEAD O THER SOURCES. REFERRING TO THE ORDER OF THE CIT(APPEALS), THE LD. D.R. SUBMITTED THAT THE REVENUE AUTHORITIES CLASSIFIED THE LAND AS DRY LAND, AND THERE IS NO EVIDENCE OF CULTIVATION OF LAND BY THE ASSESSEE. MOREOVER, THE COMPARABLE INSTANCE REPORTED BY THE A SSESSEE WAS REJECTED ON THE GROUND THAT THE VALUE WAS DETERMINE D UNDER SECTION 47A OF THE STAMP ACT. ACCORDING TO THE LD. D.R., T HE FAIR MARKET VALUE DETERMINED UNDER SECTION 47A OF THE STAMP ACT CANNOT BE A BASIS FOR COMPUTING THE FAIR MARKET VALUE UNDER SEC TION 50C OF THE ACT. THEREFORE, ACCORDING TO THE LD. D.R., THE CIT (APPEALS) HAS RIGHTLY CONFIRMED THE ORDER OF THE ASSESSING OFFICE R. 8. WE HAVE CONSIDERED THE RIVAL SUBMISSIONS ON EITH ER SIDE AND PERUSED THE RELEVANT MATERIAL AVAILABLE ON RECORD. ADMITTEDLY, THE ASSESSEE HAS SOLD A PROPERTY AT PERUMBAKKAM VILLAGE AND SHOLINGANALLUR VILLAGE. THE SHOLINGANALLUR PROPERT Y WAS TO THE EXTENT OF 4.09 ACRES AND PERUMBAKKAM VILLAGE PROPER TY WAS OF 2.02 ACRES. THE ASSESSEE CLAIMS THAT BOTH THE LANDS ARE ADJACENT TO 8 I.T.A. NO.2058/MDS/16 EACH OTHER AND THEY FORM PART OF SINGLE PIECE OF LA ND. THE ASSESSEE CLAIMS THAT THE SALE CONSIDERATION OF SHOLINGANALLU R PROPERTY WAS ` 5,73,67,520/- WHICH COMES TO NEARLY ` 215/- PER SQ.FT. THE PERUMBAKKAM VILLAGE LAND WAS SOLD FOR ` 2,20,00,000/- WHICH COMES TO ` 250 PER SQ.FT. THERE IS NO DISPUTE WITH REGARD TO VALUATION ADOPTED BY THE AUTHORITIES BELOW IN RESPE CT OF PERUMBAKKAM VILLAGE. THE VALUATION ADOPTED BY THE REVENUE AUTHORITIES IN RESPECT OF SHOLINGANALLUR PROPERTY W AS DISPUTED BY THE ASSESSEE. 9. THE FIRST CONTENTION OF THE ASSESSEE IS THAT THE LAND IN QUESTION IS AGRICULTURAL LAND, THEREFORE, IT CANNOT BE CONSIDERED TO BE CAPITAL ASSET. ADMITTEDLY, THE LAND IN QUESTION WA S CLASSIFIED AS DRY LAND. NO DOUBT, THE DRY LAND CAN ALSO BE SUBJECTED TO CULTIVATION. THE ADANGAL EXTRACT PRODUCED BY THE ASSESSEE DOES N OT DISCLOSE / INDICATE ANY CULTIVATION. THEREFORE, THIS TRIBUNAL IS OF THE CONSIDERED OPINION THAT WHEN THE LAND WAS CLASSIFIED AS DRY LA ND IN THE REVENUE RECORDS, AND ADANGAL EXTRACT DOES NOT INDICATE ANY CULTIVATION OF CROP, IT CANNOT BE CONSIDERED TO BE AGRICULTURAL LA ND AT ALL FOR THE PURPOSE OF INCOME-TAX ACT. THE MATTER WOULD STAND IN A DIFFERENT FOOTING IF THE LAND WAS CLASSIFIED AS WET LAND BY T HE STATE REVENUE 9 I.T.A. NO.2058/MDS/16 AUTHORITIES. WHEN IT WAS SPECIFICALLY CLASSIFIED A S DRY LAND, IT IS FOR THE ASSESSEE TO PRODUCE NECESSARY MATERIAL THAT THE LAND WAS UNDER CULTIVATION. ONE OF THE BASIC DOCUMENT TO PR OVE CULTIVATION IS ADANGAL EXTRACT. SINCE THE ADANGAL EXTRACT DOES NO T DISCLOSE ANY CULTIVATION, THIS TRIBUNAL IS OF THE CONSIDERED OPI NION THAT THE LAND IN QUESTION CANNOT BE CONSIDERED TO BE AS AGRICULTURAL LAND. THEREFORE, IT HAS TO BE TREATED AS CAPITAL ASSET. 10. NOW COMING TO VALUATION, AS OBSERVED EARLIER, I N RESPECT OF PERUMBAKKAM VILLAGE, THERE IS NO DISPUTE ABOUT THE VALUE ADOPTED BY THE VALUATION OFFICER AND THE ASSESSING OFFICER. THE DISPUTE IS WITH REGARD TO PROPERTY AT SHOLINGANALLUR. THE ASS ESSEE HAS PRODUCED A COPY OF THE SALE DEED TO INDICATE THAT T HE SALE CONSIDERATION DISCLOSED BY THE ASSESSEE IS THE FAIR MARKET VALUE. THIS COMPARABLE DOCUMENT PRODUCED BY THE ASSESSEE W AS REJECTED BY THE AUTHORITIES BELOW AND THE VALUATION OFFICER ON THE GROUND THAT THE FAIR MARKET VALUE WAS DETERMINED BY THE APPELLA TE AUTHORITY UNDER SECTION 47A OF THE STAMP ACT. THIS TRIBUNAL IS OF THE CONSIDERED OPINION THAT THE GUIDELINE VALUE PRESCRI BED BY THE AUTHORITIES IS ONLY TO GUIDE THE REGISTRATION AUTHO RITIES TO DETERMINE THE FAIR MARKET VALUE. THE SUB-REGISTRAR OR REGIST RATION AUTHORITY 10 I.T.A. NO.2058/MDS/16 HAS TO DETERMINE FAIR MARKET VALUE BY TAKING THE GU IDELINE VALUE AS ONE OF THE FACTORS. THE FAIR MARKET VALUE WOULD DE PEND UPON VARIOUS FACTORS SUCH AS THE LOCATION OF PROPERTY, A REA OF THE PROPERTY, POTENTIALITY FOR FUTURE DEVELOPMENT, THE INFRASTRUCTURE FACILITY AVAILABLE AROUND THE AREA AND THE INFRASTR UCTURE FACILITIES SUCH AS AIRPORT, RAILWAY STATION, BUS STAND, ETC. THEREFORE, THE GUIDELINE VALUE AS SUCH CANNOT BE CONSIDERED TO BE THE FAIR MARKET VALUE. 11. WE HAVE CAREFULLY GONE THROUGH THE PROVISIONS O F SECTION 50C OF THE ACT. SECTION 50C CLEARLY SAYS THAT WHEN THE CONSIDERATION RECEIVED BY THE ASSESSEE FOR TRANSFER OF CAPITAL ASSET IS LESS THAN THE VALUE ADOPTED OR ASSESSED BY THE A UTHORITIES UNDER THE STAMP ACT, THE MATTER CAN BE REFERRED TO THE VA LUATION OFFICER. THEREFORE, THE GUIDELINE VALUE CAN BE ONE OF THE FA CTOR FOR DETERMINING THE FAIR MARKET VALUE UNDER SECTION 50C OF THE ACT. EVEN SECTION 50C OF THE ACT CLEARLY SAYS THAT THE V ALUE ADOPTED BY THE STAMP AUTHORITIES HAS TO BE TAKEN AS MARKET VAL UE OR FULL VALUE OF CONSIDERATION FOR TRANSFER OF PROPERTY. IN THE CASE BEFORE US, THE AUTHORITIES BELOW HAS TAKEN THE GUIDELINE VALUE OF SUB-REGISTRAR AND NOT THE FAIR MARKET VALUE. OF COURSE, THE GUID ELINE VALUE WAS 11 I.T.A. NO.2058/MDS/16 HIGHER THAN THE SALE CONSIDERATION SAID TO BE RECEI VED BY THE ASSESSEE. 12. THE QUESTION ARISES FOR CONSIDERATION IS CAN TH E AUTHORITIES BELOW, INCLUDING THE VALUATION OFFICER, IGNORE THE SALE INSTANCE ON THE GROUND THAT THE VALUE WAS ADOPTED BY THE APPELL ATE AUTHORITY UNDER SECTION 47A OF THE STAMP ACT? THIS TRIBUNAL IS OF THE CONSIDERED OPINION THAT THE FAIR MARKET VALUE DETER MINED BY THE APPELLATE AUTHORITY UNDER SECTION 47A OF STAMP ACT IS ALSO ONE OF THE VALUATIONS WHICH CANNOT BE REJECTED MERELY BECA USE THE SAME WAS DETERMINED UNDER SECTION 47A OF THE STAMP ACT. MOREOVER, THE SALE INSTANCE REFERRED BY THE DEPARTM ENTAL VALUATION OFFICER WAS IN RESPECT OF SALE OF PROPERTY TO THE E XTENT OF ` 2400/- PER SQ.FT. OF LAND. IN THE CASE BEFORE US, WHAT WA S SOLD BY THE ASSESSEE IS TO THE EXTENT OF 2,66,151 SQ.FT. THERE FORE, THE COMPARISON MADE BY THE DEPARTMENTAL VALUATION OFFIC ER BETWEEN 2400 SQ.FT. AND 2,66,151 SQ.FT. IS NOT JUSTIFIED. THE COMPARISON HAS TO BE MADE IN RESPECT OF SIMILARLY PLACED PROPERTY. BY TAKING INTO CONSIDERATION OF THE LOCATION OF PROPERTY AND THE C OMPARABLE SALE INSTANCE, THIS TRIBUNAL IS OF THE CONSIDERED OPINIO N THAT THE VALUE ADOPTED FOR PERUMBAKKAM PROPERTY HAS TO BE ADOPTED FOR 12 I.T.A. NO.2058/MDS/16 SHOLINGANALLUR PROPERTY ALSO. THIS TRIBUNAL IS OF THE CONSIDERED OPINION THAT THE REPORT OF THE VALUATION OFFICER AN D REPORT OF THE REGISTERED VALUER AND SALE COMPARABLE INSTANCE MENT IONED BY THE ASSESSEE AND THE DISTRICT VALUATION OFFICER CLEARLY ESTABLISH THAT THE SHOLINGANALLUR PROPERTY CANNOT FETCH MORE THAN ` 250 PER SQ.FT. THEREFORE, THE VALUE ADOPTED BY THE ASSESSING OFFIC ER AT ` 750 PER SQ.FT. IS HIGHLY EXORBITANT. ACCORDINGLY, WHILE C ONFIRMING THE FINDING OF THE AUTHORITIES BELOW THAT THE LAND IN QUESTION IS A CAPITAL ASSET AND THE VALUATION OF PERUMBAKKAM PROPERTY AT ` 250 PER SQ.FT., THE ORDERS OF THE AUTHORITIES BELOW FIXING THE VALUE OF SHOLINGANALLUR PROPERTY AT ` 750/- PER SQ.FT. IS SET ASIDE THE ASSESSING OFFICER IS DIRECTED TO ADOPTED THE VALUE OF SHOLINGANALLUR PRO PERTY ALSO AT ` 250 PER SQ.FT. 13. IN THE RESULT, THE APPEAL FILED BY THE ASSESSEE IS PARTLY ALLOWED. ORDER PRONOUNCED ON 23 RD SEPTEMBER, 2016 AT CHENNAI. SD/- SD/- (. !' ) ( . . . ) (A. MOHAN ALANKAMONY) (N.R.S. GANESAN) $ / ACCOUNTANT MEMBER /JUDICIAL MEMBER /CHENNAI, 4 /DATED, THE 23 RD SEPTEMBER, 2016. KRI. 13 I.T.A. NO.2058/MDS/16 . ,156 76(1 /COPY TO: 1. *+ /APPELLANT 2. ,-*+ /RESPONDENT 3. 0 81 () /CIT(A)-13, CHENNAI 4. PRINCIPAL CIT-8, CHENNAI-34 5. 69 ,1 /DR 6. :' ; /GF.