Earlier-year transfer taxability controls where possession and full consideration precede later registration under property transfer rules.

An immovable property transfer completed by receipt of full consideration and delivery of possession is treated as having occurred in the earlier year under section 2(47)(v) read with section 53A of the Transfer of Property Act, so later execution or registration is only a formal step and does not shift taxability. In that setting, section 43CA does not apply in a later assessment year if the transaction had already been completed and taxed earlier. The relevant stamp duty value must correspond to the legally effective date of transfer or agreement, not a later registration date chosen for valuation.

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Issues: Whether the addition made under section 43CA of the Income-tax Act, 1961 in the relevant assessment year was sustainable when the assessee had already received the full consideration and handed over possession in the earlier year, and whether the stamp duty value as on the later registration date could be adopted.

Analysis: The transaction was found to have been completed on 13.07.2013, when the assessee received the entire sale consideration through banking channels and delivered possession of the commercial units. On these facts, the transfer was treated as having taken place in the earlier year within the meaning of section 2(47)(v) of the Income-tax Act, 1961 read with section 53A of the Transfer of Property Act, 1882. The later execution and registration of the agreement were held to be only formal acts and could not shift the point of taxation to a subsequent year. The application of section 43CA in the year under appeal was also rejected because the transaction had already been taxed in the correct year, and the valuation date used by the Department was not the legally relevant date. The alternative valuation relied upon was therefore held to be irrelevant to the assessment year in question.

Conclusion: The addition under section 43CA in the year under appeal was deleted and the issue was decided in favour of the assessee.

Ratio Decidendi: Where an immovable property transaction is completed by delivery of possession and receipt of full consideration in an earlier year, later registration does not defer taxability, and the relevant stamp duty valuation must correspond to the legally effective date of agreement or transfer, not a subsequent date chosen by the Department.

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