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For undervalued purchases of immovable property, the DVO valuation replaces the stamp-duty value when applying the safe-harbour rule under section 56(2)(x). The enhanced 10% tolerance is described as a curative, beneficial measure intended to prevent hardship in genuine transactions and therefore applies retrospectively. Where the difference between the DVO valuation and actual purchase consideration remains within that tolerance, no addition is sustainable. On this basis, the addition arising from the property valuation difference was deleted, while the claim relating to society dues became infructuous.
For undervalued purchases of immovable property, the DVO valuation replaces the stamp-duty value when applying the safe-harbour rule under section 56(2)(x). The enhanced 10% tolerance is described as a curative, beneficial measure intended to prevent hardship in genuine transactions and therefore applies retrospectively. Where the difference between the DVO valuation and actual purchase consideration remains within that tolerance, no addition is sustainable. On this basis, the addition arising from the property valuation difference was deleted, while the claim relating to society dues became infructuous.
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