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2019 (2) TMI 374 - AT - Income TaxUnaccounted investment in property - addition for undervaluation of the property in the hands of the purchaser - assessment on the basis of market valuation by Registration Authority - Held that:- It is not a denying fact that Section 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. However, there is no provision under the Income Tax Act to deal with such situation in respect of the purchase of the property. Section 56(2)(x) was inserted into the Act with effect from 1st April 2017 to deal with such situation. However, it is well settled Law that substantive provisions could not be applied retrospectively. There is no other material brought on record to justify the conclusion that assessee-company made unaccounted investment in purchase of the property. No evidence on record to justify unaccounted payment for purchase of the property, the CIT(A) was justified in deleting the additions. A.O. did not gather any evidence to establish that payments were made by the assessee-company outside the books of account. - Decided against revenue.
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