Dispute Over Stamp Duty Value for Property Sale: Assessing Officer vs. CIT(A) & ITAT on Section 43CA Interpretation.

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....The case pertains to the applicability of Section 43CA, which deals with the adoption of stamp duty value as the full value of consideration for computing profits and gains from the transfer of immovable property. The assessee executed an agreement for sale of a flat on 30/04/2011, with earnest money paid on 26/04/2011. However, the agreement was registered in the subsequent assessment year. The Assessing Officer (AO) adopted the stamp duty value on the date of registration, leading to a higher value than the agreement value. The CIT(A) held that since there was only one registered sale agreement executed during the year under consideration, the stamp duty value as on the date of the agreement should be adopted as the deemed sale considerat.........