Execution date governs registered conveyance timing, and stamp duty valuation alone cannot prove undisclosed consideration.

A registered conveyance takes effect from the date of its execution, not the date of registration, so the capital gain was attributable to the earlier assessment year and the later-year assessment could not be sustained on that basis. A stamp duty valuation, by itself, does not prove market value or receipt of extra consideration; absent independent evidence that the assessee received more than what was disclosed in the sale deed, the Revenue failed to discharge its burden and the addition was deleted. The reopening issue was left dependent on verification of the record.

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Issues: (i) Whether the assessment for the relevant year could be sustained when the transfer deed was executed in an earlier year but registered later; (ii) Whether the addition of Rs. 1,00,000 could be sustained merely on the basis of enhancement made for stamp duty purposes.

Issue (i): Whether the assessment for the relevant year could be sustained when the transfer deed was executed in an earlier year but registered later.

Analysis: A registered document operates from the date of its execution and not from the date of its registration. On the facts found, the deed was executed on 1 February 1982, and the capital gain arising from the transfer therefore pertained to the earlier assessment year. An assessment for the later year could not be made on that basis.

Conclusion: The assessment for the year under appeal was invalid and the addition made on that basis was deleted.

Issue (ii): Whether the addition of Rs. 1,00,000 could be sustained merely on the basis of enhancement made for stamp duty purposes.

Analysis: Valuation made for stamp duty collection does not, by itself, establish the market value or prove receipt of extra consideration. The burden remained on the Revenue to show that the assessee had actually received more than what was disclosed in the sale deed, and that burden was not discharged.

Conclusion: The addition of Rs. 1,00,000 was not sustainable and was deleted.

Final Conclusion: The assessee succeeded on the substantive merits, while the reopening issue was left dependent on verification of the record, and the additions made by the Revenue did not survive.

Ratio Decidendi: For a registered conveyance, the effective date is the date of execution, and a stamp duty valuation, without independent evidence of extra consideration, cannot justify an addition.

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