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    <title>2026 (6) TMI 969 - ITAT MUMBAI</title>
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    <description>Additional evidence before the appellate authority was treated as admissible where it had already been examined in remand proceedings and went to the root of the dispute; the objection to admission failed. For section 56(2)(x), the allotment date could be relevant where enforceable rights arose and substantial consideration was paid through banking channels, but the stamp duty value as on that date required limited factual verification; the addition was therefore not finally sustained. On capital gains, the holding period was counted from the allotment date, not the registration date, so the transfer was taxable as long-term capital gain and not short-term capital gain.</description>
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      <link>https://www.taxtmi.com/caselaws?id=793588</link>
      <description>Additional evidence before the appellate authority was treated as admissible where it had already been examined in remand proceedings and went to the root of the dispute; the objection to admission failed. For section 56(2)(x), the allotment date could be relevant where enforceable rights arose and substantial consideration was paid through banking channels, but the stamp duty value as on that date required limited factual verification; the addition was therefore not finally sustained. On capital gains, the holding period was counted from the allotment date, not the registration date, so the transfer was taxable as long-term capital gain and not short-term capital gain.</description>
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