Value of agriculture land

Agriculture land situated 5 kms away from corporation limit and slightly away from village panchayat limits. While purchasing in the year 2014, the Sub Registrar has given guideline rate of RS.36 L per acre. Accordingly, buyer has agreed and paid stamp duty on 36 L for an acre. Where as the sale deed is registered at Rs.6L per acre. The I.T. Dept. has issued notice to the buyer because the amount is Rs 40 L for the land. The seller has applied to the Dist. Register for revaluation and guidance value. Dist. Registrar has given the value at Rs.32 L. The real rate for the land is much less at Rs 6L per acre as per the SR for the land in the same area. What is the position of the buyer. What is the position of seller who has received amount of Rs.40L if he too receive notice from I.T.dept