Prospective application of stamp-value taxation prevents additions where property agreements and substantive payments pre-date the charging provision.

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....Section 56(2)(x)(b) taxes the excess of stamp duty value over consideration only where the property receipt falls within the charging provision's temporal scope. It operates prospectively and cannot create liability where the agreement, execution, substantial payment, or operative acquisition preceded its commencement, despite later conveyance or registration. The agreement-date valuation provisos apply only after the charging provision applies and do not independently impose tax. For covered transactions, agreement-date stamp value may be used where consideration was fixed and paid, wholly or partly, through prescribed banking or electronic modes. Tax authorities must identify the correct statutory basis and cannot change it without adequate notice and opportunity to respond.....