Per Shri T.V.K. Natarajachandran, Accountant Member - This is an appeal by the assessee which is directed against the revisional order of the CGT, Pune under section 24(2) of the Gift Tax Act, 1958 dated 25-11-1988. The CGT held that the gift-tax assessment made by the GTO under section 15(3) of the Gift-tax Act for the assessment year 1982-83 on 24-12-1986 was erroneous insofar as it was prejudicial to the interest of revenue, inasmuch as Instead of taking the market value of the property as such, he has adopted the net value of the property after deducting 50 per cent of the unearned increase in market value which was not justified. Therefore, he issued show-cause notice dated 20-9-1988 to the assessee to which the assessee has furnished reply by letter dated 6-10-1988 wherein he Justified value of gift returned at Rs. 50,000 by deducting 50 per cent of the unearned increase in market value of the property.

2. The CGT considered the objection and also the valuer’s report furnished by the assessee. The valuer has taken value of free-hold property at Rs. 20 per sq. ft. but the value of the impugned property which is subject to restrictions at Rs. 16 per sq. ft. and deducting 50