Property tax for buyers, property bought lower than market value

Hi, I recently bought a flat along with roof in an old building in calcutta for 70,00,000. This property was valued at 1,03,00,000 by Kolkata municipal corporation using their website. I was in a rush to buy the property so I didn't pay much attention and paid the seller and accordingly paid stamp duty and registration on the market value. Now i have been told by my charted accountant that I need to pay income tax on the difference between actual property price and market value which is 33,00,000 as per section 56(2)(vii). There is no chance, that flat would be worth a penny more than what I have paid, I think the valuation done by KMC is very bias and doesn't counts many factors that the building is not maintained/no lift/ and no garage as well. I refuse to pay the excess tax bec the property is being highly valued by KMC to get more stamp and revenue tax, and why should buyers now pay huge amount of tax on a pseudo profit which income tax department thinks we are making while purchasing the property, but in actual no one will ever pay me 1,03,00,000 for that property even after 5 years! Can you please advice how i can appeal against this with the income tax department?