K. RAVICHANDRABAABU, J.

1. The Revenue is on appeal in respect of the assessment year 2005-2006. The following is the substantial question of law that arise for consideration of this Court in this appeal:

"Whether on the facts and in the circumstances of the case, the Income Tax Appellate Tribunal was right in law in holding that the provisions of Section 50C can be invoked in the case where the sale of the property has not been registered, even though the assessing officer computed the long term capital gains, adopting the guideline value as the sale consideration, instead of the consideration admitted by the assessee?"

2. The assessee is an individual and filed her return of income for the assessment year 2005-2006 returning the total income of Rs.98,886/-. The assessee along with the two co-owners transferred a property measuring 23.84 cents in pursuance of an agreement of sale for consideration of Rs.50 lakhs to a third party. The agreement was not a registered one. Pursuant to the sale agreement, the physical possession of the property was handed over to the buyer and the assessee also received the sale consideration. The assessee worked out long term capital gain a