https://www.taxtmi.com/caselaws?id=466905 Revision under section 263 was not justified where the proposed addition under section 56(2)(x) depended solely on stamp duty value despite the declared purchase consideration being within the applicable tolerance limit when compared with DVO valuation. The beneficial tolerance provision was treated as applicable retrospectively. Stamp duty value does not automatically replace actual consideration without positive evidence that higher consideration passed, and the revenue bears the burden of proving such additional consideration. As no addition was warranted, the assessment was neither erroneous nor prejudicial to revenue on this issue; the revision was set aside and the assessment upheld. en-us Wed, 21 Aug 2024 00:00:00 +0530 Tue, 24 Feb 2026 16:49:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466905 Revision under section 263 was not justified where the proposed addition under section 56(2)(x) depended solely on stamp duty value despite the declared purchase consideration being within the applicable tolerance limit when compared with DVO valuation. The beneficial tolerance provision was treated as applicable retrospectively. Stamp duty value does not automatically replace actual consideration without positive evidence that higher consideration passed, and the revenue bears the burden of proving such additional consideration. As no addition was warranted, the assessment was neither erroneous nor prejudicial to revenue on this issue; the revision was set aside and the assessment upheld. Case-Laws Income Tax Wed, 21 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466905