Section 50C/56 10% Property Valuation Tolerance Applies Retrospectively: ITAT Agra

Mamta Agarwal Vs PCIT (ITAT Agra)

Tolerance band (10%) under Sec. 50C / 56 is a remedial & curative amendment &  applies retrospectively

In these two connected appeals, the assessees, Smt. Mamta Agarwal & Shri Rakesh Agarwal, had jointly purchased an immovable property wherein each of them held 1/3rd share. The actual consideration for the entire property was ₹4.71 crore, resulting in each assessee paying ₹1.57 crore. The stamp duty (circle) value of the same property was ₹9.01 crore. During the reassessment proceedings u/s 147, Assessees requested  AO to

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