https://www.taxtmi.com/caselaws?id=784281 For computing LTCG under the deeming fiction in s.50C, the dominant issue was whether the stamp valuation (SRO value) should be adopted as on the date of registered sale deeds or as on the date of the underlying agreement/settlement fixing consideration. The ITAT held that, subject to statutory preconditions, s.50C requires adoption of the SRO value prevailing on the date of the "agreement to sell"/compromise/MOU that governs the transfer, because it is that instrument which crystallizes the bargain; accordingly, SRO values as on 23.11.2013 (court-recorded compromise) and 12.08.2013 (MOUs) were directed for the covered land. For the balance land not traceable to those instruments, SRO value as on the dates of the last registered sale deeds in 11/2015 was to be adopted. The CIT(A)'s order was set aside and the AO was directed to recompute LTCG accordingly. en-us Fri, 19 Dec 2025 00:00:00 +0530 Thu, 01 Jan 2026 08:18:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784281 For computing LTCG under the deeming fiction in s.50C, the dominant issue was whether the stamp valuation (SRO value) should be adopted as on the date of registered sale deeds or as on the date of the underlying agreement/settlement fixing consideration. The ITAT held that, subject to statutory preconditions, s.50C requires adoption of the SRO value prevailing on the date of the "agreement to sell"/compromise/MOU that governs the transfer, because it is that instrument which crystallizes the bargain; accordingly, SRO values as on 23.11.2013 (court-recorded compromise) and 12.08.2013 (MOUs) were directed for the covered land. For the balance land not traceable to those instruments, SRO value as on the dates of the last registered sale deeds in 11/2015 was to be adopted. The CIT(A)'s order was set aside and the AO was directed to recompute LTCG accordingly. Case-Laws Income Tax Fri, 19 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784281