G.M. Akbar Ali, J.

1. This Tax Case (Appeal) is filed at the instance of the assessee as against the order of the Income Tax Appellate Tribunal confirming the order of the Assessing Officer and the Commissioner of Income Tax (Appeals) that the evidentiary value of the registered document is more than that of unregistered document and the provisions of Section 50C of the Income Tax Act shall be applicable.

2. The brief facts are as follows:

On 27.10.2001, the assessee entered into two sale agreements with one Smt. G.Rajamani and Shri. V.R.Govindasamy to sell the property for a total consideration of Rs.1,70,41,261/- divided as Rs.85,41,261/- for the sale to V.R.Govindasamy and Rs.85,00,000/- for the sale to Smt. G.Rajamani. The total land measuring 9,420 sq.ft. together with building thereon at Arumbakkam, Chennai was given as collateral security for the loan raised from SIPCOT. It is stated in the sale agreement that since the original title deeds were deposited with SIPCOT, the sale deeds shall be executed after the release of original title deeds. From 22.3.2002 to 28.7.2002, a sum of Rs.21 lakhs has been given to the assessee by the intending purchaser V.R.Govindasa