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    <title>2025 (6) TMI 314 - ITAT CHANDIGARH</title>
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    <description>The ITAT Chandigarh dismissed Revenue&#039;s appeals regarding profit determination under Section 43CA on shop sales and interest expense classification. For Section 43CA, the Tribunal held that valuation should be based on the agreement date (25.01.2011) when payments were made through banking channels, not later dates. Since correct stamp duty rates weren&#039;t established by AO or DVO, the declared sale deed value was accepted. Additionally, including interest charges, the total consideration differed from DVO&#039;s fair market value by less than 10%, negating any addition requirement. Regarding interest expenses on land conversion charges, the Tribunal upheld CIT(A)&#039;s decision treating them as revenue expenditure under Section 36(1)(iii) after the shopping mall became operational on 14.03.2013.</description>
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    <pubDate>Wed, 28 May 2025 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=772201</link>
      <description>The ITAT Chandigarh dismissed Revenue&#039;s appeals regarding profit determination under Section 43CA on shop sales and interest expense classification. For Section 43CA, the Tribunal held that valuation should be based on the agreement date (25.01.2011) when payments were made through banking channels, not later dates. Since correct stamp duty rates weren&#039;t established by AO or DVO, the declared sale deed value was accepted. Additionally, including interest charges, the total consideration differed from DVO&#039;s fair market value by less than 10%, negating any addition requirement. Regarding interest expenses on land conversion charges, the Tribunal upheld CIT(A)&#039;s decision treating them as revenue expenditure under Section 36(1)(iii) after the shopping mall became operational on 14.03.2013.</description>
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