Registration Act timing controls assessment year; later scanning date cannot shift registered property transactions for reassessment purposes.

Registered immovable property instruments operate from the date of execution and presentation for registration under section 47 of the Registration Act, 1908, not from a later scanning or uploading date in the registration office. On that basis, transactions executed and registered in the preceding financial year were treated as falling in the earlier assessment year, making reassessment for the year under consideration invalid. The note also states that a respondent may invoke Rule 27 of the ITAT Rules, 1963 defensively to support the order under appeal on a ground decided against it, and once reassessment failed, the Revenue's appeal could not survive.

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Issues: Whether the reassessment for the relevant assessment year was valid when the impugned immovable property transactions were executed and registered in the preceding financial year, and whether the respondent could sustain the order under Rule 27 of the ITAT Rules, 1963.

Analysis: The transactions were found to have been presented for registration and registered in the earlier financial year, and the date of scanning in the registration office could not be treated as the date of registration. By applying section 47 of the Registration Act, 1908, the registered instruments were held to operate from the date of execution and presentation for registration. On that basis, the transactions fell in the earlier assessment year and not in the year for which reassessment was initiated. The respondent was also permitted to invoke Rule 27 to support the order on the ground decided against it; once the reassessment itself was held invalid, the Revenue's appeal could not survive.

Conclusion: The reassessment for the year under consideration was invalid, and the Revenue's appeal failed.

Ratio Decidendi: A registered document operates from the date of execution and presentation for registration, not from a later administrative scanning or uploading date, and a respondent may use Rule 27 of the ITAT Rules, 1963 as a defensive ground to sustain the order under appeal.

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