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TMI Blog2024 (7) TMI 1486X X X X Extracts X X X X X X X X Extracts X X X X ..... er sources. If the parties have agreed to an agreement prior to the year where the amount of consideration is fixed, and consideration is paid in a specified manner, then stamp duty value on the date of agreement should be considered for the purpose of computing the income of the assessee. Provisions of section 50C will also apply to such provision. Thus, it is apparent that provisions of section 50C are applicable to the seller and provisions of section 56(2)(x) applies to the buyer. At present the benefit of 10% of the tolerance limit is provided under section 50C and the same tolerance limit also applies to provisions of section 56(2)(x) of the act. Therefore, in the present case the benefit of 10% of the tolerance limit should be allowe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 77; 25,264,500/ thus there was a difference of ₹ 6,944,500. The assessee was asked to explain the same. As the assessee has stated that this property was purchased in 2013 the assessee was asked to give the valuation date as 31/1/2013. No reply was received. The assessing officer referred the matter to the valuation cell to value the property as on 31/1/2013. The valuation report of the TPO was received which valued the property at ₹ 18,915,000/ therefore the learned assessing officer was the view that as per the valuation report of the district valuation officer is at ₹ 18,915,000/ whereas the assessee has disclosed consideration of ₹ 18,320,000, therefore the difference of ₹ 595,000 requires to be added to th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... mental representative vehemently stated that the assessee could not convince the learned CIT A about sufficient cause in filing the appeal and therefore he did not condone the delay and therefore the matter may be sent back to the CIT appeal. 8. We have carefully considered the rival contention and perused the orders of the learned lower authorities. We do not want to enter into the controversy whether the learned CIT A is right in condoning the delay or not. This is for the reason that if we can solve the issue on the merits here itself, there is no point in clogging the appellate system once again. on merit of the case, it shows that the stamp duty value of the property is ₹ 18,915,000/ . The transaction value of the property is ..... X X X X Extracts X X X X X X X X Extracts X X X X
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