Stamp Duty Addition Deleted – Allotment Date Prevails for Sec 56(2)(x) Valuation

ABBAS Fakhruddin Vs ITO (ITAT Mumbai) AO made addition of ₹67.56 lakh treating property purchase as unexplained investment u/s 69 / sec 56(2)(vii)(b)/(x) based on stamp duty value, as assessee had not filed return & registered value was higher than consideration (₹36 lakh). Assessee’s case: Flat allotted in 2008 via allotment letter with total consideration ₹36 lakh Payments made between 2008-2014 through banking channels (as seen in installment chart on Pg 3) Registration happened later in 2017 – no fresh investment in year ITAT held: Date of allotment = date of agreement...