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8.2 Likewise, the proviso to section 50C of the Act stipulates that stamp duty value as on the date of agreement may be considered as sale consideration instead of stamp duty value on the date of 'transfer' of the property. Sale consideration is determined between the parties at the time of entering into the sale agreement, and fair market value of the property as on the date of agreement is thus more relevant for the purpose of application of deeming provision of section50C of the Act. There may be considerable time gap in the date of agreement and the completion of the project and actual 'transfer' of the property. In most of the cases, it may be from 3 years to 10 years. In such cases, there may be considerable increase in the stamp duty value between the date of agreement and the date of transfer of property. Therefore, stamp duty value prevailing on the date of 'transfer' should not be the basis to make comparison with to the agreed sale consideration determined between the parties long ago when the agreement was entered into. However, to safeguard from the menace of entering into backdated sale agreement at lesser value and to ensure that such sale agreement are genuine in nature, ITA no.2070/AHD/2017 Asstt. Year 2011-12 second proviso to this section provides that some part of sale consideration should be transacted by banking channel on or before the date of the agreement.