https://www.taxtmi.com/caselaws?id=764304 ITAT Kolkata quashed Pr. CIT's revision order under Section 263 regarding under-assessment of income. The case involved addition under Section 56(2)(x) for differential between stamp duty valuation and purchase price in a Joint Development Agreement. The AO had initially accepted the assessee's contentions after inquiry. ITAT held that Section 45(5A) conditions for recognizing taxable income were not fulfilled as no completion certificate was obtained. The Pr. CIT's order was based on unsubstantiated assumptions rather than facts, making the adverse inference unjustified. The revision was therefore quashed in favor of the assessee. en-us Wed, 16 Oct 2024 00:00:00 +0530 Wed, 08 Jan 2025 08:37:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=764304 ITAT Kolkata quashed Pr. CIT's revision order under Section 263 regarding under-assessment of income. The case involved addition under Section 56(2)(x) for differential between stamp duty valuation and purchase price in a Joint Development Agreement. The AO had initially accepted the assessee's contentions after inquiry. ITAT held that Section 45(5A) conditions for recognizing taxable income were not fulfilled as no completion certificate was obtained. The Pr. CIT's order was based on unsubstantiated assumptions rather than facts, making the adverse inference unjustified. The revision was therefore quashed in favor of the assessee. Case-Laws Income Tax Wed, 16 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=764304