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The High Court of Allahabad dismissed the income-tax reference application under section 256(2) of the Income-tax Act, 1961. The controversy was about the valuation of an asset as of January 1, 1964, for determining capital gains. The Tribunal upheld the Income-tax Officer's valuation of Rs. 28,000 over the assessee's disclosed value of Rs. 1,50,000 in 1977. The Tribunal reasoned that the property's value could not be the same in 1964 as in 1977. The court found the Tribunal's decision supported by evidence and clarified that this case did not involve a reference under section 55A of the Act.
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