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The ITAT quashed the order of the Pr. CIT, holding that the addition u/s 56(2)(x) on differential between stamp duty valuation and purchase price was not justified. The ITAT observed that the AO had enquired and was satisfied with the assessee's contention regarding the Joint Development Agreement (JDA). The ITAT noted that taxable income u/s 45(5A) would arise only upon obtaining a completion certificate, which was not the case here. The ITAT found that the Pr. CIT's order was based on assumptions without backing of facts, contrary to the prudent businessman principle. Consequently, the ITAT ruled in favor of the assessee.
The ITAT quashed the order of the Pr. CIT, holding that the addition u/s 56(2)(x) on differential between stamp duty valuation and purchase price was not justified. The ITAT observed that the AO had enquired and was satisfied with the assessee's contention regarding the Joint Development Agreement (JDA). The ITAT noted that taxable income u/s 45(5A) would arise only upon obtaining a completion certificate, which was not the case here. The ITAT found that the Pr. CIT's order was based on assumptions without backing of facts, contrary to the prudent businessman principle. Consequently, the ITAT ruled in favor of the assessee.
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