Section 50C valuation follows the agreement-to-sell date where full consideration was received before registration.

For section 50C purposes, where the agreement to sell was executed before registration and the entire sale consideration had already been received through banking channels on that agreement date, the stamp duty valuation was taken as on the agreement date rather than the later registration date. The amendment to section 50C was treated as curative, and the later stamp valuation was not adopted for capital gains computation. The addition made by applying the registration-date valuation was deleted.

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Issues: Whether, for the purpose of section 50C, the stamp duty valuation as on the date of registration of the sale deeds or the stamp duty valuation as on the date of the agreement to sell should be adopted where the entire sale consideration had already been received through banking channels on the date of the agreement.

Analysis: The assessee transferred the lands under an agreement to sell executed on 31.12.2007 and received the entire consideration through banking channels on that date, while the sale deeds were registered later in January and February 2008. On these facts, the relevant valuation date for section 50C was held to be the date of the agreement to sell, not the later registration date. The amendment to section 50C was treated as curative in nature, and the valuation on the date of registration was held not to represent the full value of consideration for computation of capital gains in the assessee's hands.

Conclusion: The addition made by adopting the stamp valuation as on the registration date was deleted and the assessee succeeded on the section 50C issue.

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