Safe-harbour tolerance for stamp-duty valuation applies retrospectively and prevents deemed income additions for marginal property-value differences.

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....The safe-harbour tolerance-band proviso to section 56(2)(x)(b) addresses unintended hardship where purchase consideration and stamp-duty value differ only marginally. Its remedial and clarificatory character supports application from the provision's original operation, including Assessment Year 2018-19, rather than only prospectively. As the proviso is pari materia with related stamp-duty valuation provisions, a variation within the statutory tolerance margin does not sustain a deeming addition. The marginal valuation difference therefore did not justify addition as deemed income.....