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The ITAT upheld the validity of the reopening notice issued under section 147, confirming it was within the prescribed limitation period. The Tribunal rejected the assessee's challenge to the notice under section 142(1), deeming the proceedings timely. Regarding the addition under section 50C, the Tribunal accepted the assessee's evidence, including the banakhat and registered sale deed, establishing the sale price of the immovable property exceeded the Jantri value but reflected the agreed transaction amount. Citing precedent, the Tribunal held that the sale consideration as per the agreement date is determinative under section 50C, not the stamp duty value on the date of registration. Consequently, the provisions of section 50C were held inapplicable, and the assessee's appeal was allowed.
The ITAT upheld the validity of the reopening notice issued under section 147, confirming it was within the prescribed limitation period. The Tribunal rejected the assessee's challenge to the notice under section 142(1), deeming the proceedings timely. Regarding the addition under section 50C, the Tribunal accepted the assessee's evidence, including the banakhat and registered sale deed, establishing the sale price of the immovable property exceeded the Jantri value but reflected the agreed transaction amount. Citing precedent, the Tribunal held that the sale consideration as per the agreement date is determinative under section 50C, not the stamp duty value on the date of registration. Consequently, the provisions of section 50C were held inapplicable, and the assessee's appeal was allowed.
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