Tribunal held that proviso to section 43CA(1) and the subsequent amendment thereto relates back to the date on which the said section was made effective, i.e. 1st April, 2014. Referred CBDT Circular No.8 of 2018 dt. 26th December, 2018. The tolerance band was enhanced from 5% to 10% by the Finance Act, 2020 w.e.f. 1st April, 2021. (dt. 2-7-2021) (AY. 2016-17)
Stalwart Impex Pvt. Ltd. v. ITO (2021) BCAJ-September-P. 40. (Mum.)(Trib.)
S. 43CA : Transfer of assets-other than capital assets-Full value of consideration-stock in trade-Agreement value-Stamp valuation-Tolerance band from 5 % to 10%-Proviso to section 43CA(1) and the subsequent amendment thereto relates back to the date on which the said section was made effective, i.e. 1st April, 2014. [S. 50C]