Property Purchase below Circle Rate

Hi,

One of my client has brought a property below the circle rate. It is understood that the seller will be charged to capital gains tax at the circle rate even if the sale consideration is below the circle rate. But AO has made an addition in income of my client u/s 69 on account of undisclosed investment saying that one can not buy a property below circle rate. What is the correct position in this matter. Are there any case laws which we can use to counter the claim of the AO?

Anticipating good and healthy discussion.

Thanks in advance