MEENA ARJUN NARANG,MUMBAI vs. ACIT, CIRCLE 27(2), MUMBAI, MUMBAI

ITA 6651/MUM/2025Status: DisposedITAT Mumbai24 December 2025AY 2018-19Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)1 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the stamp duty valuation should be considered as on the date of the allotment letter, not the date of the agreement, as part payments were made through banking channels prior to the agreement. The addition made by the AO was directed to be deleted.

What were the facts?

The assessee purchased an immovable property in 2010, with an allotment letter and partial payments made. The property was completed in 2017, and the agreement value was lower than the stamp duty value on the date of agreement, leading to an addition under section 56(2)(x).

What were the issues?

The primary issue was whether the stamp duty valuation for the purpose of Section 56(2)(x) should be taken on the date of allotment or the date of the agreement, considering prior part payments.

Which sections of the Income-tax Act were involved?

Section 56(2)(x),Section 147,Section 148,Section 143(2),Section 142(1)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “SMC” BENCH, MUMBAI

Before: SHRI AMIT SHUKLA, JM & SHRI ARUN KHODPIA, AM

For Appellant: Shri Dhaval Shah, AR
For Respondent: Shri Nakul Agrawal, Sr. DR
Hearing: 22.12.2025Pronounced: 24.12.2025

Per Arun Khodpia, AM: This appeal is filed by the assessee against the order of Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre (NFAC), Delhi [for short “ld. CIT(A)”] dated 24.12.2024 for the AY 2018-19, which in turn arises from the assessment order passed under section 147 r.w.s. 144 of the Income Tax Act, 1961 (the Act) dated 15.03.2023 passed by Assessment Unit, Income Tax Department. The grounds of appeal raised by the assessee are as under: Meena Arjun Narang “1. Validity of reopening of assessment

On the facts and circumstances of the case and in law, the Learned Commissioner of

The order continues below.

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