Prospective operation of stamp-value taxation excludes property purchases agreed and substantially paid for before the charging provision commenced.

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....Section 56(2)(x)(b), introduced by the Finance Act 2018 and applicable from Assessment Year 2019-20, operates prospectively. It cannot tax the difference between purchase consideration and stamp value where an immovable-property purchase agreement was executed in 2013 and substantial consideration was paid through banking channels before the provision was inserted. On those facts, the stamp-value-difference addition was deleted and the appellate order sustaining it was set aside.....