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    <title>2026 (3) TMI 629 - ITAT MUMBAI</title>
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    <description>Allotment letters dated 08.05.2010 were held to qualify as agreements to sell because they fixed consideration and were followed by part payments through non cash banking channels on or before that date; therefore the provisos to the income tax valuation rule require using the stamp duty value as on 08.05.2010 rather than on the later registration date. Absent contemporaneous stamp valuations for that earlier date, the matter is remitted to the Assessing Officer for the limited purpose of comparing transaction value with stamp duty valuation as on the allotment date after giving the assessee an opportunity to be heard.</description>
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