High Court of Karnataka · Judgments and reasoned final orders
Principal Commissioner of Income Tax & Anr. v. Bellandur Chikkagurappa Jayaramareddy
I.T.A. No. 372/2022 ·
Agreement-date stamp valuation sustained under section 50 C on the case-specific payment and agreement facts.
1. FACTS OF THE CASE
Revenue appealed the Tribunal’s 5 January 2022 order in ITA 1322/Bang/2019 for AY 2014-15. Its proposed questions challenged use of the 8 April 2013 MOU date for guidance value and the finding that the part-consideration condition was met, stressing that the MOU was unregistered.
2. DISCUSSION BY THE COURT
The Court accepted use of the agreement date on this factual matrix. It reproduced the first two provisos to section 50 C(1), including the condition concerning receipt of consideration through specified banking modes on or before the agreement date, and found Revenue’s case outside the exceptions.
3. JUDICIAL DECISION
Revenue’s appeal was rejected as without merit, with costs made easy. The Tribunal’s relief remained undisturbed.
4. OUTCOME
The assessee succeeded on the agreement-date valuation issue; an unregistered MOU was not treated as independently transferring title.
5. Expert Comments
AKHB editorial analysis, distinct from the Court’s findings.
Separate valuation date from transfer of title
Revenue’s title objection did not defeat the section 50 C valuation conclusion on these facts. The judgment is about the relevant stamp-value date, not a declaration that an unregistered MOU itself conveys ownership.
Source: PDF p. 3
Read the payment condition with the agreement-date proviso
The reproduced second proviso requires qualifying receipt on or before the agreement date. The Court’s result cannot be reduced to a rule allowing every earlier agreement date irrespective of payment evidence.
Source: PDF p. 5
Keep the historical year qualification visible
The source addresses AY 2014-15 while acknowledging later introduction of the provisos. This case note reports that application without inventing a general retrospective rule or relying on the source’s inconsistent amendment annotations as verified legislative history.
Source: PDF p. 3
Source and verification
Complete 5-page supplied source; all pages read.
Original PDF: 5 pages · SHA-256: 4b58273ecd275fa6f5421957e4f951c6c0930ea20922c3e4adda6a1e31298323
Complete source text and every original page visually reviewed; identity and SHA-256 checked. AI-assisted source analysis.
The judgment concerns AY 2014-15 and applies the agreement-date provisos in that case. Its reproduced statutory amendment annotations are not independently verified legislative history or current-law clearance.
Subsequent judicial treatment has not been independently verified.
AI disclosure and professional disclaimer
AI-assisted source review. Independent human approval is not represented.
General research only. Read the complete judgment and verify applicable law and subsequent treatment before reliance.