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    <title>2025 (9) TMI 1820 - ITAT MUMBAI</title>
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    <description>Addition under section 56(2)(x) for alleged undervaluation of immovable property was held unjustified because the property had been allotted earlier, the consideration was fixed in the allotment letter, and part payment had been made through banking channels before registration. The Tribunal applied the CBDT clarification that, where the agreement date and registration date differ and part consideration is paid by bank on or before the agreement date, the stamp duty value on the agreement date may be adopted. As the declared consideration was supported by the earlier allotment and matched the co-owner&#039;s accepted treatment, the proviso was held applicable and the addition deleted.</description>
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      <description>Addition under section 56(2)(x) for alleged undervaluation of immovable property was held unjustified because the property had been allotted earlier, the consideration was fixed in the allotment letter, and part payment had been made through banking channels before registration. The Tribunal applied the CBDT clarification that, where the agreement date and registration date differ and part consideration is paid by bank on or before the agreement date, the stamp duty value on the agreement date may be adopted. As the declared consideration was supported by the earlier allotment and matched the co-owner&#039;s accepted treatment, the proviso was held applicable and the addition deleted.</description>
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