SWATI ATUL KADAKIA ,MUMBAI vs. ITO 16(3)(1), MUMBAI

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “SMC”, MUMBAI

BEFORE SHRI S. RIFAUR RAHMAN, HON'BLE ACCOUNTANT MEMBER

ITA NO.338/MUM/2023 (A.Y: 2018-19) Swati Atul Kadakia v. Income Tax Officer – 16(3)(1) Room No. 447 1302, Vasant Aradhana Tower Aayakar Bhavan, New Marine Lines Mahavir Nagar, Kandivali (W) Mumbai - 400020 Mumbai - 400067 PAN: AABPK8725D (Appellant) (Respondent)

Assessee Represented by : Shri Rashmikant Modi & Shri Ketki Rajshirke Department Represented by : Shri S.N. Kabra

Date of Hearing : 05.04.2023 Date of Pronouncement : 15.05.2023 O R D E R PER S. RIFAUR RAHMAN (AM)

ITA NO.338/MUM/2023 (A.Y: 2018-19) Swati Atul Kadakia 2. Brief facts of the case are, assessee has filed her return of income declaring income of ₹.7,74,480/- on 19.07.2018. The case was selected for scrutiny on the issue of specific information pointing tax evasion has been received from another agency. Accordingly, notices u/s. 143(2) and 142(1) of Income-tax Act, 1961 (in short “Act”) were issued and served on the assessee through NeAC.

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ITA NO.338/MUM/2023 (A.Y: 2018-19) Swati Atul Kadakia ₹.95,82,696/-. Accordingly, assessee was asked to why difference of purchase amount as per agreement and stamp duty value i.e., ₹.18,74,696/- should not be taxed as income u/s. 56(2)(x)(B) of the Act.

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ITA NO.338/MUM/2023 (A.Y: 2018-19) Swati Atul Kadakia Officer proceeded to make the addition of ₹.9,37,350/- as income of the assessee.

“A. Difference of Rs. 9,37,350/- has been added in Income 1) The reason for difference between the purchase amount as per agreement i.e. Rs.77,08,000/- and amount as stamp duty act i.e. Rs.95,82,696/- is because the assessee has booked the apartment in Dec-2013 and agreed the consideration in Dec- 2013 itself. The assessee has also started making the payment for the purchase of property from Dec-2013 onwards through proper banking channel. However, the agreement was registered on 31st March 2018 as the building was under construction as per agreement with builder. The assessee has executed the purchase agreement in the year under consideration. Thus, the difference only due to time difference. Further Section 56(2)(x)(b) clearly states that- Where any person receives, in any previous year, from any person or persons on or after the 01st Day of April, 2017 any immovable property (A) without consideration, the stamp duty value of which exceeds fifty thousand rupees, the stamp duty value of such property. (B) for a consideration, the stamp duty value property of such property as exceeds such consideration, if the amount of such excess is more than the higher of the following amounts namely: 1. the amount of fifty thousand rupees, and 2. the amount equal to [five] percent of the consideration:] Provided that where the date of agreement fixing the amount of consideration for the transfer of immovable property and the date

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ITA NO.338/MUM/2023 (A.Y: 2018-19) Swati Atul Kadakia of registration are not the same, the stamp duty value on the date of agreement may be taken for the purpose of this sub-clause: Provided further that the provisions of the first provision shall apply only in a case where the amount of consideration referred to therein, or a part of thereof has been paid by way of an account payee cheque or an account payee bank draft or by use of electronic clearing system through a bank account on or before the date of agreement or transfer of such immovable property As per the first proviso to section 56(2)(x)(b) of the Income- tax Act, 1961 (Act) where the date of agreement fixing the amount of consideration for the transfer of immovable property and the date of registration are not the same, the stamp duty value on the date of agreement fixing the amount of sale consideration may be considered. As per the allotment letter dated 19th December 2013 attached with the Final Purchase Agreement with both parties the assessee and the Shivam Megastructures Private limited have confirmed the Price of the Flat of Rs. 79, 18,800/- in December 2013 for Flat No. 1504, B Wing Shivam Imperial Heights, (later on Name changed to Godrej Tranquil) Kandivali. Further the assessee also made a payment of Rs. 37,09,400/- as per details given in receipt on Page No. 43 of the said Purchase Agreement. Further the assessee has also paid Service Tax of Rs. 1,14,620/- as per the Invoice dated 1 September 2014 raised by the builder before the Registration of Purchase Agreement. Further the assessee has also paid MVAT of Rs. 35,594/- as per Demand Letter dated 8th June 2017 received from Shivam Megastructures Private Limited. Thus, it is evident from the payment made to the builder & various taxes paid to the government for the purchase of flat, that the flat was originally booked by the assessee in December 2013, amount of sale consideration was fixed and it is clearly acknowledged in the agreement for purchase registered in March 2018 by attaching to the agreement booking letter dated 19th December 2013, Payment Schedule and Service Tax Invoice dated 11th September 2014 with the agreement. Thus, the Stamp Duty Value applicable at the time of booking of the flat is to be considered as per proviso to section 56(2)(x)(b) because the sale consideration and all major terms and conditions for purchase of flat has been agreed by both the parties in December 2013. Further, it needs to be checked whether the consideration for the flat on the date of allotment is higher than the Stamp Duty value as on that date. In the event the answer is in affirmative, the transaction will be held to be good. Refer CIT v. Vummudi Amarendran (2020) 429 ITR 97 /(2021) 277 Taxman 243 (Mad.) Page No. | 5

ITA NO.338/MUM/2023 (A.Y: 2018-19) Swati Atul Kadakia (HC) the Court held that as regards, Stamp valuation, amendment with effect from 1-4-2017. Statutory amendment is made to remove an undue hardship- Amendment retrospective. Thus, the value as per stamp duty acts as on date of allotment and fixation of consideration was much lower than the purchase act, 1961. Hence the said difference of Rs. 18, 74,696/- between the agreement value and stamp duty value cannot be treated as income in the hands of the assessee for the year under consideration.”

“7.2 Finding on Grounds of Appeal No. 1, 2 and 3 a) The Appellant has relied on the Option letter dated 19.12.2013 issued to Appellant by Shivam Megastructures Pvt Ltd. This option letter is regarding the expression of desire by Appellant to buy 2 BHK Flat admeasuring 679 sq. feet (carpet area) in B wing on 15th floor with one car parking space in proposed project of Shivam Megastructures Pvt Ltd in Akurli Road, Kandvali West, Mumbai. It is subject to several terms & conditions. The most important fact that is revealed from the above option letter is that Flat No. 1504 is not mentioned in this allotment letter. Appellant has expressed her desire and interest to have an option to purchase a 2 BHK Flat in the proposed project. The Builder decides to grant the Appellant an option to acquire a 2 BHK Flat measuring 679 sq. feet in B wing in proposed project on 15th Floor. Actual identification of Flat shall depend on the plans of proposed project being finalized which are still at planning stage. Area/layout/Floor plans etc of proposed project are still under preparation and approval of concerned authorities is pending. They may change and area of flat may change. Intimation of Approval (10A) and commencement certificate has yet to be obtained from concerned authorities. In case of delayed payment then the option granted under this letter shall lapse. In case the Appellant fails to make the payments in time then Builder is entitled to terminate this option letter. These facts show that this is not an Allotment letter as claimed by Appellant but on option letter which is clearly stated in the said letter.

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ITA NO.338/MUM/2023 (A.Y: 2018-19) Swati Atul Kadakia b) Appellant expressed desire to purchase 2 BHK Flat admeasuring 679 sq. feet (carpet area) in B wing with one car parking space on 15th Floor but the Flat number is not mentioned in option letter.  Company decides to grant Appellant the option to acquire the said property which shall be reserved for Appellant until the option lapses. It is not allotment letter of Flat No. 1504 but an option given to Appellant to purchase flat on 15th floor in B wing of the proposed project which is still at the design stage.  If the area of flat changes beyond 10% of carpet area as discussed the Appellant is entitled to terminate this option and seek refund.  Planning and design shall be finalized by 31.03.2014 and approved by concerned authorities shortly.  Builder will complete construction in 42 months from the date of commencement of work. Otherwise interest @ 18% p.a. will be given for period of delay.  Appellant will acquire this property on payment of Rs.11,94,600/- on or before 28.02.2014 which is Advance Price.  Option price of Rs.36,92,400/- shall be paid as mentioned in Annex A annexed herewith.  The further amount of Rs.41,92,400/- will be paid as mentioned in Annex B annexed herewith.  This payment is exclusive of MVAT, work contract tax, GST, TDS, Service tax etc payable for sale/purchase of property.  Stamp Duty and Registration charges will be borne by buyer only.  This option letter is signed by Director of Shivam Megastructures on one side and Appellant and her husband on other side stating "I accept & confirm the above terms and conditions."  The above facts show that as per the above option letter the Flat No. 1504 has not been allotted to Appellant. Appellant has expressed his option and desire to purchase a flat on 15th floor measuring 679 sq. feet in B wing of the proposed project which is still in planning and design stage.

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ITA NO.338/MUM/2023 (A.Y: 2018-19) Swati Atul Kadakia  So this option letter cannot be said as Allotment Letter as Flat No.  1504 has not been allotted to Appellant vide this option letter. c) Thus, the basic question that arises is that "whether the booking rights to Flat accrued to Appellant on date of issue of option letter or on the date of execution of Agreement to sell". d) The option letter makes it very clear that the time of payment of all installments as per the "Agreement to sell" is the essence of contract and the said agreement to sell will be executed shortly. In case of any default in payment of installments as per 'Agreement to sell' this offer shall stand automatically cancelled. e) Only an 'Agreement to sell' intends to convey these "rights or interest in property" and can be considered as the source of accrual of "rights or interest in property" to Appellant. Thus the 'right or interest in property' accrues to Appellant only by way of an "Agreement to sell". f) The option letter shows that no right to claim title/ownership results from the option letter in hands of Appellant. These rights to claim title/ownership in property accrues to Appellant when the 'Agreement to sell' is signed by both the parties. As per this option letter, there is no intention to convey the rights to claim title ownership to Appellant. Thus it is clear that right to claim title/ownership or booking rights do not accrue to Appellant from the option letter. These rights accrue to Appellant on the signing of 'Agreement to sell' between both the parties. g) The right to obtain conveyance of immoveable property accrues in hands of Appellant on signing the Agreement to sell or Buyers agreement and it does not accrue in hands of Appellant on issue of option letter. The right to obtain title to flat or booking right accrues to Appellant on signing of Agreement to sell. h) By the virtue of option letter it cannot be held that Appellant had possession of Flat, enjoyment of property i.e. Flat or significant interest in the said flat. These rights came to possession of Appellant after the signing of 'Agreement to sell'. Thus by virtue of option letter it cannot be said that the option letter of Flat can be included in the ambit of capital asset u/s 2(14) of Act. 7.3 In view of the facts and discussion as outlined in para 7.2 of the order the action of AO in adding Rs.9,37,350/- as Income from other sources is upheld. Grounds of Appeal No. 1 to 3 are dismissed.” Page No. | 8

ITA NO.338/MUM/2023 (A.Y: 2018-19) Swati Atul Kadakia 9. Aggrieved assessee is in appeal before us raising following grounds in its appeal: -

“1. On the facts and in the circumstances of the case, the Appellant submits that the Hon'ble Commissioner of Income Tax (Appeals), Mumbai erred in upholding the addition of Rs. 9,37,350/- made u/s 56(2)(x)(B) made by the Assessing Officer in the assessment order passed. The Appellant submits that the addition of Rs. 9,37,350/- made u/s 56(2)(x)(B) be deleted. 2. On the facts and in the circumstances of the case, the Appellant submits that the Hon'ble Commissioner of Income Tax (Appeals), Mumbai erred in concluding that there was no agreement to sale made prior to the date of registration and further erred in ignoring the subsequent payments made by the Appellant otherwise than by cash for the purchase of the flat in pursuance to the offer made, allotment of flat by the builder pursuant to the offer letter and therefore erred in considering the offer letter in isolation of the subsequent action of payment made by the Appellant and allotment of the said flat by the builder as not an agreement to sale made prior to the date of registration. The Appellant submits that the there was an agreement to sale before the date of registration. 3. On the facts and in the circumstances of the case, the Appellant submits that the provision I and proviso 2 of Section 50 Cr.w.3. 56(2)(x)(B) are applicable in the case of the Appellant and accordingly stamp duty valuation of the flat on the date of allotment of the flat be considered instead of stamp duty valuation on the date of registration for computing the addition, if any to be made u/s 56(2)(x)(B). The Appellant submits that the stamp duty valuation of the flat on the date of allotment be considered. 4. On the facts and in the circumstances of the case, the Appellant submits that the Hon'ble Commissioner of Income Tax (Appeals) erred in upholding that valuation of the flat on the date of allotment is self-made. The Appellant submits that the valuation of the flat as on the date of allotment as per the valuation certificate from the registered

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ITA NO.338/MUM/2023 (A.Y: 2018-19) Swati Atul Kadakia valuer provided during the course of assessment proceedings and the valuation was not self made. 5. The Appellant craves leave to reserve to itself the right to add, after, amend or annul any of the grounds of appeal at or before the time of hearing and to produce such further evidences, documents and papers as may be necessary.”

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ITA NO.338/MUM/2023 (A.Y: 2018-19) Swati Atul Kadakia the sale consideration of ₹ 77,08,000/- in order to purchase Flat No. 1504, with the carpet area of 62.61 Sq.Mts along with one car parking. Ld. AR submitted that valuation has to be adopted on the date of entering into the original sale agreement not on the date of actual registration. He relied on the following case law: -

a. CIT v. Vummudi Amarendran [2020] 120 taxmann.com 171 (Madras) b. Parth Dashrath Gandhi v. Addl./Dy./ACIT in ITA.No. 1990/Mum/2022 dated 31.03.2023 c. ITO v. Rajni D. Saini in ITA.No. 7120/Mum/2018 dated 09.11.2022.

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ITA NO.338/MUM/2023 (A.Y: 2018-19) Swati Atul Kadakia rejected contention of the assessee with the observation that assessee has valued the property by self and it is not by a registered valuer. However, we observe that assessee has filed copy of the valuation report from Devand K. Dadbhawala which was duly submitted before the Ld.CIT(A) and as per the valuation report the valuer valued the property on 01.04.2013 at the value of ₹.53,09,214/-. Therefore, the contention of the assessee that valuation has to be adopted on the date of entering into the original sale agreement not on the date of the date of actual registration is proper and justified.

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ITA NO.338/MUM/2023 (A.Y: 2018-19) Swati Atul Kadakia the initial agreement entered by the assessee seems proper agreement and the date of agreement has to be reckoned in order to compare the stamp duty valuation. Accordingly, the assessee has submitted proper valuation from the authorised valuer as on 01.04.2013 and he has also considered the rate from the ready reckoner 2013. Therefore, the findings of the Ld.CIT(A) that the initial agreement is only a proposal not a final agreement is not proper and against the facts on record.

“6. We heard the parties and perused the record. We notice that the AO has considered the stamp duty value as on the date of registration of the agreement to sell for the purpose of determining the applicability of sec.56(2)(x) of the Act. However, the facts that the assessee had been allotted both the properties by way of allotment letters and further, the assessee has also paid instalments as per that letter are not disputed. Hence, the question that arises is whether the allotment letter can be considered as “agreement to sale” within the meaning of the provisos to sec. 56(2)(x) of the Act, which states that the stamp duty valuation as on the sale of sale agreement should be taken into consideration for the purpose of sec.56(2)(x), provided that amount of consideration or part thereof had been paid as per the mod prescribed on or before the date of agreement for transfer of such immovable property. 7. Before us, the Ld A.R placed reliance on the decision rendered by the co-ordinate bench in the case of Mr. Sajjanraj Mehta vs. ITO (ITA No.56/Mum/2021 dated 05-09-2022), wherein it was held that the date of allotment letter can be taken as date of agreement of sale for the purposes of sec.56(2)(x) of the Act. On the contrary, the Ld D.R placed his reliance on the decision Page No. | 13

ITA NO.338/MUM/2023 (A.Y: 2018-19) Swati Atul Kadakia rendered by another co-ordinate bench, which was relied upon by AO & CIT(A), viz., Sujauddian Kasimsab (supra). 8. With regard to the decision rendered in the case of Sujauddian Kasimsab (supra), the Ld A.R submitted that the said decision has been rendered on the basis of facts prevailing in that case. The assessee, in the above said case, had paid Rs.3.00 lakhs before the date of agreement, but the same was described as “earnest money deposit” in the Agreement, meaning thereby, the assessee did not fulfill the condition prescribed in sec.56(2)(x) of the Act. The Ld A.R further submitted that the Tribunal did not consider the effect of second proviso to sec.56(2)(x) of the Act in the above said case. We agree with the submissions of Ld A.R with regard to the distinguishing features pointed out in the decision rendered by the co-ordinate bench in the case of Sujauddian Kasimsab (supra). Hence, we are of the view that the above said decision could not lend support to the case of the revenue. 9. On the contrary, we are of the view that the decision rendered by another co-ordinate bench in the case of Mr Sajjanraj Mehta (supra) is applicable to the facts of the present case. The decision rendered in the case of Mr Sajjanraj Mehta by the co- ordinate bench is extracted below, for the sake of convenience:- “10. We have gone through the order of the A.O, Ld. CIT(A) and various submissions of assessee dated 06- 10-2021. Vide pg no-23 to 27 of paperbook we have observed the payment made by the assessee to the developer on 17-102011 amounting to Rs 14 lacs vide cheque no 906740, Bank of Maharashtra to enter into an agreement cum acknowledgement of payment made and other terms and conditions about the property. This agreement between assessee and developer clearly confirms the amount of consideration along with other terms and conditions relating to levy of stamp duty, service tax and other charges to be paid by the assessee. 11. The finding of the A.O vide pg no-4, para-2.6 wherein he observed that assessee has deposited Rs 14 lacs with the developer to year mark the said premises for Rs 70 lacs. Even if for the time being it is assumed that this agreement is merely a letter of intent, still amount mentioned in this so called letter of intent can’t be changed by either of the party .At the max the parties involved may opt for exit from the transaction but amount of consideration can’t be changed. This transaction of the assessee has to be analysed in

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ITA NO.338/MUM/2023 (A.Y: 2018-19) Swati Atul Kadakia commercial parlance, without finalisation of consideration nobody will deposit 20% of the final consideration. The vitality of the agreement further found force from the behaviour of the assessee as confirmed by the A.O also that assessee paid further Rs 34.5 lacs till financial year 2012-13. Assessee also paid Rs 1,00,285/- as VAT, Rs 1,35,187/- as service tax, Rs 5,02,000/- as stamp duty and Rs 30,000/- as registration charges. 12. The chronology of the events confirms that the finding of the A.O treating the agreement of the assessee as letter of intent is not correct. In this matter treating the said agreement as letter of intent shows an over thinking and hyper technical interpretation at the end of the A.O. assessee’s case clearly falls in the proviso to Section 56(2)(vii)(b). For sake of clarity we are reproducing herein below the relevant portion of proviso “Provided that where the date of the agreement fixing the amount of consideration for the transfer of immovable property and the date of registration are not the same, the stamp duty value on the date of the agreement may be taken for the purposes of this sub-clause: Provided further that the said proviso shall apply only in a case where the amount of consideration referred to therein, or a part thereof, has been paid by any mode other than cash on or before the date of the agreement for the transfer of such immovable property”. 13. We further relied on following judicial pronouncement of coordinated benches of ITAT, Hon’ble High Court and Apex Court as under: a. “Siraj Ahmed Jamalbhai Bora vs. ITO Ward- 1(3)(1)ITA No. 1886/M/ 2019 dtd. 28/10/2020, (Mum.) (Trib.): Date of registration irrelevant for Sec 56(2)(vii)(b) as substantial obligation discharged on date of agreement. b. Radha Kishan Kungwani vs. ITO Ward - 1(2) ITA No. 1106/JP/2018 dtd. 19/08/2020, [185 ITD 433 (Jaipur - Trib.)]

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ITA NO.338/MUM/2023 (A.Y: 2018-19) Swati Atul Kadakia Where assessee entered into agreement for purchase of flat and had made certain payment at time of booking of flat, stamp duty valuation or fair market value of immovable property was to be considered as on date of payment made by assessee towards booking of flat c. Sanjay Dattatraya Dapodikar v/s ITO Ward - 6(2), Pune ITA No. 1747/PN/2018 dtd. 30/04/2019(Pune) (Trib) Where date of agreement for fixing amount of consideration for purchase of a plot of land and date of registration of sale deed were different but assessee, prior to date of agreement, had paid a part of consideration by cheque, provisos to section 56(2)(vii)(b) being fulfilled, stamp value as on date of agreement should be applied for purpose of said section d. Ashutosh Jhavs. ITO Ward-2(5), Ranchi ITA No. 188/Ranchi/2019 dtd. 30/04/2021, [190 ITD 450 (Kolkata - Trib.).] Where assessee purchased a property and made part payment of sale consideration by cheque on very next day of execution of purchase agreement and registry was done after a year, since such part payment made by cheque on very next day of execution of agreement was towards fulfilment of terms of purchase contract itself and there was no mala fide or false claim on part of assessee, no addition could be made on account of difference between amount of sale consideration for property shown in purchase agreement and stamp duty value of said property on date of registry by invoking section 56(2)(vii)(b) e. Dy. CIT-5(3)(1) vs. Deepak Shashi Bhusan Roy ITA No. 3204 & 3316/M/2016 dtd. 30/07/2018(Mum.) (Trib.) In order to determine taxability of capital gain arising from sale of property, it is date of allotment of property which is relevant for purpose of computing holding period and not date of registration of conveyance deed f. Mohd. Ilyas Ansari v. ITO-23(2)(3),Mumbai [ITA No. 6174/M/2017 dtd. 06/11/2020, 186 ITD 407 (Mumbai - Trib.)] Where Assessing Officer mechanically applied provisions of section 56(2) to difference between stamp duty value Page No. | 16

ITA NO.338/MUM/2023 (A.Y: 2018-19) Swati Atul Kadakia and actual sale consideration paid by assessee and made additions, without making any efforts to find out actual cost of property, additions made by Assessing Officer were to be set aside.” 14. Similar property in the case of assessee’s wife with similar transactions has been accepted by the same A.O without any addition for the same A.Y. Here we would like to rely on the decision of Hon’ble Gauhati HC. “Gulabrai Hanumanbox. vs. Commissioner of Wealth- tax [198 ITR 131 (Gauhati) (HC).] Two different Assessees having similar/identical facts w.r.t valuation of property cannot be assessed with different rates for the same property. Thereby, the order passed by the Assessing officer for co-sharer of property is arbitrary and unjustified in law” 15. Keeping in view the facts of the case, chronology of events and respectfully following the pronouncements of the co-ordinated benches of ITAT, we delete the addition made by A.O and confirms that assessee is entitled to the benefits of proviso to Section 56(2)(vii)(b).” 10. Accordingly, following the above said decision, we hold that the respective allotment letters issued to the assessee should be considered as “Agreement to sell” for the purposes of sec.56(2)(x) of the Act. Since the assessee has paid the parts of consideration as per the terms and conditions of allotment through banking channels prior to the execution of Sale agreement, we are of the view that the provisos to sec.56(2)(x) shall apply to the facts of the present case. Accordingly, the stamp duty valuation as on the date of respective Allotment letters should be considered for the purposes of sec.56(2)(x) of the Act. Hence the AO was not justified in considering the stamp duty valuation as on the date of execution of agreement to sell. 11. On a perusal of record, we notice that the details of stamp duty value as on the date of respective allotment letters was not brought on record. Since we have held that the stamp duty valuation as on the date of respective allotment letters should be considered for the purpose of sec.56(2)(x) of the Act, it is imperative on the part of the assessee to show that the actual consideration was equal or less than the stamp duty valuation as on the date of issue of respective allotment letters. Accordingly, we are restoring this issue to the file of AO for the limited purpose of comparing the actual sale consideration with the stamp duty Page No. | 17

ITA NO.338/MUM/2023 (A.Y: 2018-19) Swati Atul Kadakia valuation as on the date of respective allotment letters. In the limited set aside, the AO shall take appropriate decision in accordance with law after affording adequate opportunity of being heard.”

Order pronounced in the open court on 15th May, 2023

Sd/- (S. RIFAUR RAHMAN) ACCOUNTANT MEMBER Mumbai / Dated 15/05/2023 Giridhar, Sr.PS Copy of the Order forwarded to: 1. The Appellant 2. The Respondent. 3. CIT 4. DR, ITAT, Mumbai 5. Guard file. //True Copy// BY ORDER

(Asstt. Registrar) ITAT, Mum

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