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Issues: Whether section 56(2)(x) of the Income-tax Act, 1961 applied to an immovable property transaction where the deed of conveyance was executed on 31.03.2017 but registered on 13.04.2017, and whether the stamp duty value had to be tested with reference to the date of execution or the date of registration.
Analysis: The relevant charging provision under section 56(2)(x) applies to receipt of immovable property on or after 01.04.2017, but the effect of a compulsorily registrable conveyance depends on the legal operation of the instrument. Applying section 47 of the Registration Act, 1908, the deed, once registered, operates from the date of execution where the transaction was already completed and consideration had been paid. The statutory provisos to section 56(2)(x) do not alter the operative date of the conveyance; they only provide a mechanism for adopting the agreement-date stamp value in specified cases. The later registration date therefore did not convert an otherwise pre-01.04.2017 transaction into one governed by section 56(2)(x).
Conclusion: Section 56(2)(x) was not applicable to the transaction, and the addition made on that basis could not survive.
Final Conclusion: The assessee succeeded on the jurisdictional objection, the Revenue's challenge failed, and the substantive addition was held unsustainable.
Ratio Decidendi: For purposes of section 56(2)(x), a registered conveyance may relate back to its date of execution where the transaction was completed earlier and the operative transfer took place before the provision came into force.
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