ITAT Mumbai – Addition U/s 56(2)(vii)(b) Deleted as Stamp Value Difference within 10% Tolerance Band

Chandra Lalit Sanghvi Vs ITO (ITAT Mumbai) AO reopened assessment u/s 147 r.w.s. 144B & made addition of ₹81.99 lakh u/s 56(2)(vii)(b) on purchase of property, being difference between actual consideration and stamp duty valuation. The CIT(A) granted partial relief by restricting addition to assessee’s 1/3rd share (₹27.33 lakh), but sustained balance addition. Before ITAT, the assessee contended that the variation between purchase consideration (₹8.27 cr) and stamp value (₹9.09 cr) was only 9.91%, i.e., within 10% tolerance band introduced through amendments to sec. 50C/56, which...