Taxpayer Not Liable for Retroactive Application of Income Tax Act Section 43CA on Pre-2014 Sale Agreements.

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....Addition u/s 43CA - difference in the value taken for stamp duty and the actual sale consideration - the provisions to section 43CA have been introduced w.e.f. 01.04.2014 and the ‘agreement to sell’ was entered prior to the 1st April 2014 and therefore, the condition of payment or part payment of consideration on or before the date of agreement cannot be imposed back-dated as the assessee could not have foreseen the introduction of section 43CA. - AT....