Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Extended period of limitation unsustainable; allowable deductions for prompt payment discounts, pro rata recovery, freight and VAT led to demand being...
The Tribunal held that the enhancement of the stamp duty valuation tolerance band from 5% to 10% was a curative, beneficial amendment applicable to A.Y. 2018-19, because it only relaxed the rigour of a deeming provision and did not create a new charge or fresh burden. It further held that the deeming fiction under section 56(2)(x)(b)(B) could not be invoked where the difference between the purchase consideration and the stamp duty value was 7.44%, being within the 10% band. The addition was deleted.
The Tribunal held that the enhancement of the stamp duty valuation tolerance band from 5% to 10% was a curative, beneficial amendment applicable to A.Y. 2018-19, because it only relaxed the rigour of a deeming provision and did not create a new charge or fresh burden. It further held that the deeming fiction under section 56(2)(x)(b)(B) could not be invoked where the difference between the purchase consideration and the stamp duty value was 7.44%, being within the 10% band. The addition was deleted.
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