https://www.taxtmi.com/caselaws?id=784469 The dominant issue was whether an addition representing the taxpayer's 50% share under s.56(2)(x) arising from a difference between declared purchase consideration and stamp duty value could be rectified under s.154 by applying the statutory 10% tolerance ("safe harbour"). Relying on co-ordinate bench reasoning that the 10% tolerance under ss.43CA/50C/56(2)(x) is a benevolent provision intended to mitigate marginal valuation variations, the Tribunal held it operates retrospectively and its non-application constituted a mistake apparent from the record amenable to rectification. Consequently, the impugned order was quashed, the relief granted through the s.154 rectification order was sustained/restored, and the taxpayer's appeal was allowed. en-us Tue, 16 Sep 2025 00:00:00 +0530 Tue, 06 Jan 2026 08:47:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784469 The dominant issue was whether an addition representing the taxpayer's 50% share under s.56(2)(x) arising from a difference between declared purchase consideration and stamp duty value could be rectified under s.154 by applying the statutory 10% tolerance ("safe harbour"). Relying on co-ordinate bench reasoning that the 10% tolerance under ss.43CA/50C/56(2)(x) is a benevolent provision intended to mitigate marginal valuation variations, the Tribunal held it operates retrospectively and its non-application constituted a mistake apparent from the record amenable to rectification. Consequently, the impugned order was quashed, the relief granted through the s.154 rectification order was sustained/restored, and the taxpayer's appeal was allowed. Case-Laws Income Tax Tue, 16 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784469