Sunday, 15 September 2024

Understanding the Nuances of Section 43CA

 1.      Applicability: Section 43CA specifically applies to land or buildings held as stock-in-trade (i.e., by builders). It seeks to address undervaluation in property transactions by relying on the SVA-assessed value, which is the basis for calculating stamp duty according to state government rules.

2.      Comparison of Sale Consideration and SVA Value: If the sale consideration (the price the seller claims to have received) for the land or building is lower than the value determined by the SVA, the SVA value will be deemed the actual sale consideration for tax purposes. This ensures that tax is paid on a higher, more accurate property value rather than an artificially reduced sale price.

3.      110% Safe Harbor Rule: There is a provision that allows some flexibility in this comparison. If the SVA-assessed value does not exceed 110% of the actual sale consideration, then the actual consideration received will be taken as the sale price for tax purposes, and the tax will be calculated accordingly. This rule provides relief in cases where the difference between the two values is minimal.

4.      Challenge to SVA Value: If the seller believes the SVA value is higher than the fair market value at the time of transfer, they have the option to dispute this. The seller can request the tax officer to refer the case to a valuation officer (VO) for an independent valuation. However, this option is available only if the SVA value has not been disputed in any court or legal proceeding

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