Dy.CIT v. Sutlej Agro Products Ltd. (2019) 70 ITR 33 (SN) (Delhi)(Trib.)

S. 50C : Capital gains-Full value of consideration-Stamp valuation-Purchase of property-Applicable to seller and not purchaser-Unaccounted income invested in the purchase of property.[S. 56(2)(x), 132, 153C]

S. 50C is applicable in the case of the seller of the property to take into consideration the valuation of the property as per the value adopted by the Registration Authority and there is no provision under the Income-tax Act to deal with a situation in respect of the purchase of the property.  If there is no other material brought on record to justify the conclusion that assessee company made unaccounted investment in purchase of the property no addition can be made.  S. 56(2)(x) of the Income-tax Act was inserted into the Act with effect from 1st April 2017 and cannot apply retrospectively.