The assessee company during the year under consideration had transferred Flats for a sale consideration of Rs.42,40,000/-. The AO observed that  sale consideration was lower than the value of Rs. 74,23,500/- that was adopted by the Sub-registrar, Government of Maharashtra and issued show cause notice to add the difference as deemed income. In response to notice the assesseee contended that ‘agreements’ were registered in respect of the additional area purchased by the tenants besides the area to which they were entitled free of cost pursuant to the re-development agreement that was entered into by them with the society. It was the claim of the assessee that the stamp duty value comprised of the cost of construction of the area which was agreed to be given free of cost to the tenants, and also the cost of land, building and the construction cost of the additional area that was purchased by the said tenant. On the basis of his aforesaid claim, it was submitted by the assessee that as the sale consideration as per the “agreement” was only in respect of the additional area purchased by the tenants, therefore, what could be considered for the purpose of applying S. 43CA was the stamp duty value of such additional area, which as per the assessee worked out at Rs.46,88,350/- and not Rs.74,23,500/-. It was also contended that as the aforesaid difference worked out to 9.56% of the stamp duty value which was less than 15%, was to be ignored and no addition was called for in its case. Alternatively, it was submitted by the assessee, that if at all the deemed income of Rs.4,48,350/-was to be assessed, the same could be brought to tax only in the year when the revenue was recognised in respect of the aforesaid flats as per the method of accounting regularly followed by the assessee. CIT(A) confirmed the order of the AO. On appeal the Tribunal held that,  there is no substance in the claim of the assessee that as per the pre-amended provision of S..43CA, in case the difference between the value adopted by the stamp valuation authority and the actual sale consideration was less than 15%, then the same was to be ignored and no addition on the said count was called for in the hands of the assessee. As per the doctrine of statutory interpretation, no word howsoever meaningful it may so appear can be allowed to be read into a statutory provision unless the same had specifically been therein provided for. As observed by us hereinabove, it is only vide the Finance Act, 2018, w.e.f 01.04.2019, that as per the ‘proviso’ incorporated in S. 43CA(1) that the legislature in all its wisdom had provided for a tolerance limit of 5% as regards the difference between the value adopted by the stamp valuation authority and the actual consideration received or accruing as a result of transfer of the asset (other than a capital asset). As such, it is only w.e.f 01.04.2019, if the value adopted or assessed or assessable by the stamp valuation authority for the purpose of payment of stamp duty does not exceed one hundred and five per cent of the consideration received or accruing as a result of the transfer of the asset (other than a capital asset), then the consideration so received or accruing as a result of the transfer, for the purposes of computing the profits and gains from transfer of such asset, was to be deemed to be the full value of consideration. Accordingly, as long as the difference between the value adopted by the stamp valuation authority and the actual consideration received or accrued to the assessee on the transfer of the asset (other than a capital asset) is not in excess of five percent, then such difference is to be ignored and the profits and gains on transfer of the asset has to be worked out on the basis of the actual consideration received or accruing to the assessee. In case, the aforesaid claim of the assessee that if the difference between the value adopted by the stamp valuation authority and the actual consideration received or accruing as a result of transfer of the asset (other than a capital asset) does not exceed 15%, then no addition would be called for under S.43CA is accepted, then we are afraid that the same would render the aforesaid ‘proviso’ to S.. 43CA(1) as had specifically been made available on the statute vide the Finance Act, 2018 w.e.f. A.Y. 2019-20 would be rendered as meaningless. (AY. 2015-16)