#ITAT precedent

ITAT Delhi holds that the 10% tolerance limit under Section 50C of the Income Tax Act applies retrospectively, deleting a Rs. 4.47 lakh addition for a minor valuation discrepancy in property sales. The ruling clarifies that valuation differences within the tolerance limit cannot justify additions to capital gains, impacting taxpayers contesting stamp duty-based assessments.

ITAT Nagpur ruled that where previous orders consistently taxed only the gross profit margin on unrecorded cash sales, the entire cash amount cannot be added as unexplained income under Section 69A without new, material evidence. This reinforces stare decisis in tax litigation, protecting assessees from arbitrary reassessments when consistent precedent exists.