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    <title>2025 (8) TMI 443 - ITAT MUMBAI</title>
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    <description>Under section 56(2)(x), an earlier allotment letter and part payment did not displace the final registered agreement, because the assessee accepted the operative consideration in the later instrument and failed to prove that the earlier arrangement survived independently. The Tribunal therefore rejected the plea to use 2010 as the valuation date or to extend the first and second provisos on that basis. It also held that the transaction did not belong to the earlier assessment year, as the document was presented for registration only in 2019 and the surrounding record did not support relation back. The 2019 DVO valuation was upheld because no effective contrary valuation evidence was produced.</description>
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      <title>2025 (8) TMI 443 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=776256</link>
      <description>Under section 56(2)(x), an earlier allotment letter and part payment did not displace the final registered agreement, because the assessee accepted the operative consideration in the later instrument and failed to prove that the earlier arrangement survived independently. The Tribunal therefore rejected the plea to use 2010 as the valuation date or to extend the first and second provisos on that basis. It also held that the transaction did not belong to the earlier assessment year, as the document was presented for registration only in 2019 and the surrounding record did not support relation back. The 2019 DVO valuation was upheld because no effective contrary valuation evidence was produced.</description>
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