https://www.taxtmi.com/caselaws?id=443582 ITAT Delhi dismissed the revenue's appeal and upheld the CIT(A)'s deletion of additions made under s. 43CA, holding that the deeming provisions could not be applied to transactions where substantial consideration was received and allotment letters were issued prior to the insertion of s. 43CA (w.e.f. AY 2014-15). The Tribunal accepted that stamp duty valuation as on the date of later sale agreements could not substitute the agreed consideration fixed earlier. On the assessee's appeal, ITAT reversed the CIT(A)'s confirmation of addition in respect of one allottee's transaction, ruling that receipt in cash in an earlier year could not be used to deny the benefit of pre-existing agreement value, as s. 43CA could not be applied retrospectively. en-us Mon, 29 May 2023 00:00:00 +0530 Wed, 03 Dec 2025 17:32:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=443582 ITAT Delhi dismissed the revenue's appeal and upheld the CIT(A)'s deletion of additions made under s. 43CA, holding that the deeming provisions could not be applied to transactions where substantial consideration was received and allotment letters were issued prior to the insertion of s. 43CA (w.e.f. AY 2014-15). The Tribunal accepted that stamp duty valuation as on the date of later sale agreements could not substitute the agreed consideration fixed earlier. On the assessee's appeal, ITAT reversed the CIT(A)'s confirmation of addition in respect of one allottee's transaction, ruling that receipt in cash in an earlier year could not be used to deny the benefit of pre-existing agreement value, as s. 43CA could not be applied retrospectively. Case-Laws Income Tax Mon, 29 May 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=443582