The earlier allotment letters had, according to the Assessing Officer, never been finally acted upon or executed. Per contra, the learned Authorised Representative (AR) strongly relied upon the order of the learned CIT(A) and submitted that the relief granted by the learned CIT(A) calls for no interference. The Assessing Officer has not recorded any finding that the earlier allotment dated 01.11.2001, the MOU dated 25.06.2003 or the revised allotment dated 07.05.2009 was cancelled, rescinded or abandoned. On the contrary, the earlier allotment formed part of the chain of documents leading to the final registration. The Assessing Officer, therefore, was not justified in mechanically adopting the stamp duty value as on the date of registration by disregarding the earlier allotment, MOU, revised allotment and payments through banking channels.