Transfer effective on possession, Not registration – ITAT applies Section 2(47)(v)- Section 43CA cannot override completed Transfer: ITAT Mumbai

Navketan Premises Pvt. Ltd Vs DCIT (ITAT Mumbai)

Transfer effective on possession, Not registration – ITAT applies Section 2(47)(v)- Section 43CA cannot override completed Transfer  : ITAT Mumbai; DVO Valuation irrelevant when sale & possession completed in prior year

The issue before the Tribunal was the addition of ₹3.56 crore u/s 43CA for alleged undervaluation in sale of commercial property based on stamp duty/DVO valuation, rather than declared sale consideration.

Assessee, a real estate developer, sold four commercial units in “H

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