K.P. VARGHESE vs THE INCOME TAX OFFICER,ERNAKULAM, AND ANOTHER

The Supreme Court held that Section 52(2) of the Income Tax Act, 1961 requires proof of understatement of consideration for a property transfer to invoke its provisions. The Court clarified that the burden of proof lies with the Revenue to establish such understatement. The Court allowed the appeal, ruling that the reassessment based on an alleged fair market value exceeding the declared consideration was invalid without evidence of actual understatement.