Stamp duty value under section 56(2)(x)(b)(B) depends on allotment-date valuation when payment precedes registration.

Where immovable property is booked under an earlier allotment letter and consideration is paid through banking channels before the registered agreement, the first proviso to section 56(2)(x)(b)(B) requires stamp duty value to be taken on the agreement or allotment date, not the later registration date. The appellate record also noted that valuation material and ready reckoner value for the earlier year were relevant to determine the correct statutory comparison, so additional evidence was admitted for proper adjudication. The Assessing Officer was directed to verify the authenticity and correctness of those documents, and the addition based on the registration-date value was sent back for fresh examination.

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Issues: Whether, for the purpose of section 56(2)(x)(b)(B) of the Income-tax Act, 1961, the stamp duty value was to be taken as on the date of registration or on the date of allotment/agreement where consideration had been paid through banking channels before the agreement; and whether the additional evidence relating to valuation and ready reckoner value should be admitted.

Analysis: The property was booked under an allotment letter issued in an earlier financial year, and the consideration was paid through banking channels before the registered agreement. In such a situation, the first proviso to section 56(2)(x)(b)(B) requires adoption of the stamp duty value as on the date of agreement/allotment, not the later registration date. The valuation report and ready reckoner value for the earlier year were material to determine the correct statutory comparison, and their production at the appellate stage was found necessary for proper adjudication. The additional evidence was therefore admitted, with a direction that the Assessing Officer verify its authenticity and correctness.

Conclusion: The addition based on the registration-date stamp duty value was found to be inconsistent with section 56(2)(x)(b)(B), and the matter was sent back for fresh examination of the allotment-date valuation and supporting documents.

Final Conclusion: The assessee obtained appellate relief in the form of remand for fresh verification, and the disputed addition was not finally sustained at this stage.

Ratio Decidendi: Where consideration for immovable property is paid through prescribed banking modes on or before the date of the agreement or allotment, the stamp duty value relevant under section 56(2)(x)(b)(B) is the value on that earlier date, not the registration date.

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