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    <title>Non-retrospective application of Section 56(2)(x): agreements concluded before enactment not taxable despite later registration under income tax law</title>
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    <description>ITAT held that Section 56(2)(x) cannot be applied retrospectively to a property transfer concluded by agreement in 2010; the tribunal accepted uncontested facts that substantial payments and possession occurred after the 2010 agreement and that subsequent registration in 2018 did not convert the pre-existing transaction into one chargeable under that provision. CIT(A)&#039;s technical dismissal on advance-tax and belated return grounds did not address the substantive legal point. Applying the principle that a provision does not apply to agreements concluded prior to its enactment, the addition under Section 56(2)(x) was deleted and the appeal allowed for AY 2018-19.</description>
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    <pubDate>Sat, 07 Mar 2026 08:39:18 +0530</pubDate>
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      <title>Non-retrospective application of Section 56(2)(x): agreements concluded before enactment not taxable despite later registration under income tax law</title>
      <link>https://www.taxtmi.com/highlights?id=97471</link>
      <description>ITAT held that Section 56(2)(x) cannot be applied retrospectively to a property transfer concluded by agreement in 2010; the tribunal accepted uncontested facts that substantial payments and possession occurred after the 2010 agreement and that subsequent registration in 2018 did not convert the pre-existing transaction into one chargeable under that provision. CIT(A)&#039;s technical dismissal on advance-tax and belated return grounds did not address the substantive legal point. Applying the principle that a provision does not apply to agreements concluded prior to its enactment, the addition under Section 56(2)(x) was deleted and the appeal allowed for AY 2018-19.</description>
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      <pubDate>Sat, 07 Mar 2026 08:39:18 +0530</pubDate>
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