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Shrichand Raheja And Another vs S.C. Prasad, (Appropriate Authority) ... on 28 September, 1994

With great respect, we find it difficult to subscribe to the view taken by the Bombay High Court in Srichand Raheja & Anr. Vs. S.C. Prasad (Appropriate Authority) and Ors. (1995) 213 ITR 33, inter alia, holding that the expression "as on the date of such agreement for transfer" refers only to the expression of "such consideration" appearing earlier and not to the discounted value; the date of agreement for transfer is relevant only for the purpose of ascertaining the fair market value by the Appropriate Authority; it has no relation to the date of determination of the discounted value and, therefore, the discounted value is to be determined with reference to the date of payment under Section 269UG(1) of the Act and not with reference to the date of the agreement.
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