Held that the proviso to section 43CA(1) allowing a 10 per cent tolerance band by the Finance Act, 2020, with effect from 1-4-2021, is curative and applies retrospectively; hence, no addition was warranted in the case of the assessee, where the difference between the DVO value and the sale consideration was within the permissible limit for the assessment year 2018-19. (AY. 2018-19)
DCIT v. Gaurav Investments. (2025) 215 ITD 124 (Mum) (Trib.)
S.43CA: Transfer of assets-other than capital assets-Full value of consideration-stock in trade-Agreement value-Stamp valuation-Allowing 10 per cent tolerance band is curative and applies retrospectively-No addition was warranted in case of assessee, where difference between DVO value and sale consideration was within permissible limit for assessment year 2018-19.[S.50C]
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