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As per multiple grounds of appeal, the assessee has essentially raised two grievances : (i) applicability of amended provisions of s. 56(2)(vii)(b) of the Act in the facts and circumstances of the case; and (ii) chargeability of interest under s. 234B of the Act on additions made. It is not in dispute that purchase transactions of immovable property were carried out in financial year 2011-12 for which full consideration was also parted with the seller. Mere registration at later date would not cover a transaction already executed in the earlier years and substantial obligations have already been discharged and a substantive right has accrued to the assessee therefrom. The preamended provisions will thus apply and therefore the Revenue is debarred to cover the transactions where inadequacy in purchase consideration is alleged. We thus find merit in the issue raised on behalf of the assessee. The order of the CIT(A) is accordingly set aside and the AO is directed to delete the additions made under s. 56(2)(vii)(b) of the Act and restore the position claimed by the assessee.

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Sec. 56(2)(vii)(b) of Income-tax Act, 1961— Income from other sources—Mere registration at later date would not cover a transaction already executed in the earlier years and substantial obligations have already been discharged and a substantive right has accrued to the assessee therefrom. Where an individual or HUF receives from any person any immovable property without consideration, the provisions of preamended s. 56(2)(vii)(b) would apply and the aforesaid provisions was however substituted by Finance Act, 2013 and made applicable to asst. yr. 2014-15 onwards and.the preamended provisions will thus apply in the case of the assessee and therefore the Revenue is debarred to cover the transactions where inadequacy in purchase consideration is alleged, thus, the AO is directed to delete the additions made under s. 56(2)(vii)(b) and restore the position claimed by the assessee— Bajrang Lal Naredi vs. ITO [2020] 203 TTJ 925 (RANCHI)

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