“Section 56(2)(vii)(c)”

Section References (mined)Section 56Section 56(2)(vii)(c)57 judgments

The decision most relied on for Section 56(2)(vii)(c) is Sudhir Menon HUF v. ACIT (45 Taxmann.com 176), cited in 21 judgments on BharatTax.

Leading authorities on Section 56(2)(vii)(c)

Sudhir Menon HUF v. ACIT

45 Taxmann.com 176 · 2014 · ITAT

citing judgments

Section 56(2)(vii)(c) does not apply to additional shares allotted pro rata to existing shareholders, as there is no scope for any property being received in such a situation.

CIT v. Jalan Hard Coke Ltd.

95 Taxmann.com 330 · 2018 · High Court

citing judgments

An addition made to income for unexplained share capital is unsustainable if the assessee fails to produce the share applicants, as the assessee cannot be tasked with finding those individuals.

M.J. Siwani v. CIT

53 Taxmann.com 318 · 2015 · Supreme Court

citing judgments

The dismissal of a Special Leave Petition (SLP) by the Supreme Court does not, in itself, constitute a judgment affirming the High Court's decision. It signifies that the Supreme Court did not find sufficient grounds to interfere with the High Court's findings.

CIT v. Madan Teatres Ltd.

260 CTR 75 · 2013 · High Court

citing judgments

Penalty cannot be imposed when the addition to income is solely on account of the valuation officer's estimation of fair market value.

54 of the Act.: 1. Ashok G. Chauhan v. Asstt. CIT

105 Taxmann.com 204 · 2019 · Reported

citing judgments

An assessee claiming deduction under Section 54F is not disentitled if they are a co-owner of another residential property, as fractional ownership does not violate the conditions of the section.

Hunsur Plywood Works Ltd. v. CIT

229 ITR 112 · 1998 · Supreme Court

citing judgments

The issuance of bonus shares is merely a capitalization of profits and does not constitute a distribution of profits or a gift to shareholders, as they are essentially receiving certificates entitling them to participate in the company's reserves as part of the capital.

Judgments citing Section 56(2)(vii)(c)

Lupin Investments Private Limited (Successor to Zyma Laboratories Limited), Mumbai vs. Deputy Commissioner of Income Tax - 14(2)(1), Mumbai

In the result, appeal of the assessee is allowed in part for statistical purposes

ITA 4635/MUM/2024[2016-17]Status: DisposedITAT Mumbai09 Jul 2025AY 2016-17

Bench: Shri Narendra Kumar Billaiya, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Ble

For Appellant: Shri P.J. Pardiwalla, Shri Pratik PoddarFor Respondent: Shri Rajesh Kumar Yadav, CIT, D/R

Section 115QSection 142(1)Section 143(2)Section 143(3)Section 234BSection 250Section 35ASection 56(2)(viia)Section 80G

आयकर अपीलीय अधिकरण न्यायपीठ, मुंबई । IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, MUMBAI BEFORE SHRI NARENDRA KUMAR BILLAIYA, HON

ACIT-CC-7(3), Mumbai vs. Mangalprabhat Gumanmal Lodha, Mumbai

In the result, appeal of the revenue is dismissed

ITA 2246/MUM/2025[2014-15]Status: DisposedITAT Mumbai04 Jul 2025AY 2014-15

Bench: Shri Narendra Kumar Billaiya, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Ble

For Appellant: Shri Niraj Seth, A/RFor Respondent: Shri Aditya M. Rai, Sr. D/R

Section 24Section 56(2)(vii)

heard both the parties, perused materials available on record and gone through orders of the authorities below. As per the provisions of section 56(2)(vii)(c) of the Act, if difference between consideration paid for purchase of property and guideline value of said property, then said difference should ... tolerance band, then said difference cannot be considered as deemed consideration in the hands of the seller and consequently the provisions of section 56(2)(vii)(c) of the Act cannot be invoked in the hands of the buyer. Since, difference between guideline value and consideration paid for purchase

Thermodyne Dynamics Private Limited, Hyderabad vs. Income-Tax Officer, Ward -17(3), Hyderabad

ITA 500/HYD/2024[2013-2014]Status: DisposedITAT Hyderabad03 Jul 2025AY 2013-2014

Bench: Us :

For Appellant: Shri Pawan KumarFor Respondent: Shri B. Balakrishna -CIT-

Section 11USection 143(2)Section 143(3)Section 14ASection 234BSection 56

judgment of the Hon’ble Apex Court in Khoday Distilleries Ltd. Vs. CIT & Anr. (supra), has observed that the provisions of Section 56(2)(vii)(c) of the Act will not apply to the issuance of new shares. The Ld. AR 13 Thermodyne Dynamics Private Limited Vs. ITO submitted that ... High Court in the aforementioned case was, inter alia, sought by the revenue for adjudicating the scope of a similarly worded Section 56(2)(vii)(c) of the Act on the following question of law:- "Whether in the facts and circumstances of the case and in law, the learned ITAT

Smt. Prema Mukesh Jhalani, Mumbai vs. ITO Ward 3(2), Thane

In the result the appeal filed by the assessee stands allowed

ITA 4753/MUM/2024[2011-12]Status: DisposedITAT Mumbai16 Jun 2025AY 2011-12

Bench: Hon‟Ble Shri Vikram Singh Yadav & Shri Sandeep Gosainsmt. Prema Mukesh Jhalani Vs. Ito, Ward 3(2) 1 A/34, Drugs Society, Opp. Room No. 4, 6Th Floor, Jk Gram, Samatha Nagar B-Wagle Estate, Midc, Pokhran Road No. 1 Thane (W) Thane (W). Pan/Gir No. Aaupj0472D (Applicant) (Respondent) Assessee By Shri Nishit Gandhi Revenue By Shri Chetan M. Kacha, (Sr. Dr) Date Of Hearing 23.04.2025 Date Of Pronouncement 16.06.2025 आदेश / Order Per Sandeep Gosain, Jm: The Present Appeal Has Been Filed By The Assessee Challenging The Impugned Order 22.08.2024 Passed U/S 250 Of The Income Tax Act, 1961 („The Act‟), By The National Faceless Appeal Centre, Delhi (Nfac) For The Assessment Year 2011-12. 2. All The Grounds Raised By The Assessee Are Interrelated & Interconnected & Relates To Challenging The Order Of Ld. Cit(A) In Upholding The Order Of Ao In Reopening The 2 Smt. Prema Mukesh Jhalani, Mumbai

Section 250Section 56Section 56(2)(vii)

donor to the appellant on 09/04/2009 itself, as per the letters of the donors as referred above. Now, the provisions of section 56(2)(vii)(c) of the I. T. Act, 1961 were introduced for the first time w.e.f ... shares were already gifted in the name of the appellant by the donors prior to that. Thus, the provision of section 56(2)(vii)(c) of the I. T. Act, 1961 is not applicable to the Appellant so far, the above-mentioned gifts are concerned. It is only because

ACIT Circle-28(1), New Delhi vs. Ajay Singh, New Delhi

In the result, appeal of Revenue is allowed for statistical purpose

ITA 912/DEL/2020[2015-16]Status: DisposedITAT Delhi30 May 2025AY 2015-16

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraआअसं.912/िद"ी/2020(िन.व. 2015-16) Assistant Commissioner Of Income Tax, Circle 28(1), R. No. 1001, 10Th Floor, E-2, Block, Pratyaksh Kar Bhawan, Civic Centre, ...... अपीलाथ"/Appellant J L Nehru Marg, New Delhi 110002 बनाम Vs. Ajay Singh, B-1, Kalindi Colony, New Delhi 110065 ..... "ितवादी/Respondent Pan: Abjps-9222-J Assessee By : None Department By : Shri Javed Akhtar, Cit(Dr) सुनवाई क" ितिथ/ Date Of Hearing : 03.03.2025 घोषणा क" ितिथ/ Date Of Pronouncement : : 30.05.2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Revenue Is Directed Against The Order Of Commissioner Of Income Tax (Appeals)-10, New Delhi (Hereinafter Referred To As 'The Cit(A)') Dated 06.12.2019, For Assessment Year 2015-16. 2. The Revenue In Appeal Has Assailed The Order Of Cit(A) By Raising Following Grounds:-

For Appellant: NoneFor Respondent: Shri Javed Akhtar, CIT(DR)

Section 147Section 56(2)(vii)Section 56(2)(viii)

made by the AO to the income of the assessee on account of provisions of section 56(2)(vii)(c) of the IT Act ignoring the fact that the assessee has acquired shares for a consideration which is less than aggregate fair market value of the shares? 2. Whether ... made by the AO to the income of the assessee on account of provisions of section 56(2)(vii)(c) of the IT Act ignoring the fact that shares of Spice jet purchased by assessee are quoted and there is no other method of valuation prescribed in case of locked

Rupesh Laldas Dhakate, Nagpur vs. ITO Ward -1, Bhandara

In the result, appeal of the assessee is allowed

ITA 185/NAG/2025[2017-18]Status: DisposedITAT Nagpur27 May 2025AY 2017-18

Bench: Shri V. Durga Rao

For Appellant: Shri Chandraprakash BhutadaFor Respondent: Shri Surjit Kumar Saha

Section 147Section 156Section 48Section 50CSection 69

relative, such as a father, is exempt from tax irrespective of the value of the gift. The court noted that as per Section 56(2)(vii)(c), a lineal ascendant (father) is treated as a relative, and therefore, gifts received from a father, even if they exceed ₹50,000, will

Ushasree Bandaru, Hyderabad vs. DCIT., Circle-5(1), Hyderabad

In the result, appeals filed by the assessee are allowed

ITA 529/HYD/2024[2016-17]Status: DisposedITAT Hyderabad20 May 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.528/Hyd/2024 (निर्धारण वर्ा/Assessment Year: 2016-17) Satyasree Kamineni Vs. Dy.Commissioner Of Hyderabad Income Tax [Pan :Adopk6338C] Circle-5(1) Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita No.529/Hyd/2024 (निर्धारण वर्ा/Assessment Year: 2016-17) Ushasree Bandaru Vs. Dy.Commissioner Of Hyderabad Income Tax [Pan :Acepb2973M] Circle-5(1) Hyderabad निर्धाररती द्वधरध/Assessee By: Shri K.C.Devdas, Ar रधजस् व द्वधरध/Revenue By: Shri B.Bala Krishna, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 01/05/2025 घोर्णध की तधरीख/ 21/05/2025 Date Of Pronouncement: आदेश / Order Per Vijay Pal Rao: These Two Appeals Filed By The Two Related Assessees Are Directed Against Two Separate Orders Of Principal Commissioner Of Income Tax (“Ld.Pcit”) Both Dated 26.03.2024 Passed U/S 263 The Income Tax Act, 1961 (“The Act”) For The Assessment Year 2016-17. Identical Grounds Have Been Raised By Both The Assessees. The Grounds Raised In The Ita No.528/Hyd/2024 Are Reproduced As Under :

For Appellant: Shri K.C.Devdas, ARFor Respondent: Shri B.Bala Krishna, CIT-DR

Section 142(1)Section 147Section 148Section 263Section 56(2)(vii)

that the shares issued by the company are the fresh allotment and therefore, the same does not fall in the mischief of section 56(2)(vii)(c) of the Act. In support of his contentions, he has relied upon the judgement of Hon’ble Gujarat High Court in the case ... Right issue shares and therefore, the same cannot be said to be received from any person, which is fundamental requirement for invoking section 56(2)(vii)(c) of the Act. Thus, the Ld.AR has contended that the Hon’ble High Court has held that for invoking the provisions of section

Satyasree Kamineni, Hyderabad vs. DCIT., Circle-5(1), Hyderabad

In the result, appeals filed by the assessee are allowed

ITA 528/HYD/2024[A.Y.2016-17]Status: DisposedITAT Hyderabad20 May 2025

For Appellant: Shri K.C.Devdas, ARFor Respondent: Shri B.Bala Krishna, CIT-DR

Section 142(1)Section 147Section 148Section 263Section 56(2)(vii)

ACIT, Central Circle-1, Thane vs. Nakul Markhedkar, Thane

ITA 786/MUM/2025[2015-16]Status: DisposedITAT Mumbai30 Apr 2025AY 2015-16

Bench: Shri Saktijit Dey, Vp & Ms Padmavathy S, Am

For Respondent: Shri Rakesh Ranjan - Sr. DR

Section 132Section 153ASection 56(2)(vii)

issue contended by the revenue in both the appeals pertain to the CIT(A) deleting the addition made by the AO under section 56(2)(vii)(c) of the Income Tax Act, 1961 (the Act) by applying Rule 11UA of the Income Tax Rules, 1962 (the Rules). 2 ... business as EPC contractor, which makes it very clear that acquisition of holding companies was arranged only to circumvent the provisions of section 56(2)(vii) (c) of the I.T.Act, 1961. 5. The assessee has failed to explain satisfactorily the source of capital Rs. 14.03 crores raised by M/s. Ratangiri

ACIT, Central Circle-1, Thane vs. Nakul Markhedkar, Thane

ITA 785/MUM/2025[2016-17]Status: DisposedITAT Mumbai30 Apr 2025AY 2016-17

Bench: Shri Saktijit Dey, Vp & Ms Padmavathy S, Am

For Respondent: Shri Rakesh Ranjan - Sr. DR

Section 132Section 153ASection 56(2)(vii)

Raj Kumar Narang, Noida vs. ITO, Ward- 4(2), New Delhi

In the result, appeal of the assessee is allowed

ITA 4914/DEL/2019[2015-16]Status: DisposedITAT Delhi07 Apr 2025AY 2015-16

Bench: Sh. Sudhir Kumar & Sh. Manish Agarwalassessment Year: 2019-20 Jaipal Jain Vs Deputy Commissioner Of H. No. 1248 Sector 11-12 Income Tax, Central Circle Huda Haryana Karnal Pan No. Abipj3891M (Appellant) Respondent

Section 143(3)Section 153ASection 153DSection 49(4)Section 56(2)(vii)

this case the co-ordinate bench held as under: 7. On facts, the AO in the instant case invoked the provision of section 56(2)(vii)(c) of the Act in respect of shares allotted to the assessee @ INR 40/- per share against the rights entitlement being existing shareholder ... thus INR 4/- per share were deemed as income from other sources. The assessee made out a case that the provision of section 56(2)(vii)(c) do not apply in view of section 49(4) of the Act and in view of the existing entitlement which partakes the character

Manjulaben Jayantibhai Patel, Khambhat vs. The Addlcit, National Faceless Assessment Centre, Delhi Juridictional AO : the ITO, Ward- 1(3)(1), Petlad

In the result, the appeal of the assessee stands allowed

ITA 1559/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad24 Mar 2025AY 2016-17

Bench: Shri Sanjay Gargassessment Year 2016-17

For Appellant: Ms. Arti N. Shah, A.RFor Respondent: Shri Ashok Kumar Suthar, Sr. D.R

Section 147Section 147rSection 56(2)(vii)

THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD “SMC” BENCH Before Shri Sanjay Garg, Judicial Member Assessment Year 2016-17 Manjulaben The

Sunny Tarunkumar Doshi, Jetpur vs. The ITO, Ward-1(1)(1), Ahmedabad

In the result, appeal filed by the assessee is dismissed

ITA 288/AHD/2021[2014-15]Status: DisposedITAT Ahmedabad14 Feb 2025AY 2014-15

Bench: Smt. Annapurna Gupta & Ms. Suchitra Kambleassessment Year: 2014-15

Section 142(1)Section 143(3)Section 147Section 148Section 234ASection 271(1)(c)Section 56(1)(vii)Section 56(2)(vii)Section 69A

same has been started. In alternate, the ld. AR submitted that the reference to DVO should be made for the valuation if Section 56(2)(vii)(c) and the proviso clearly determines that the DVO’s report should be taken into consideration. 6. The Ld. DR submitted that the reopening

Deputy Commissioner of Income Tax, Agra vs. Gausia Cold Storage Private Limited, Mumbai

Appeal is dismissed

ITA 1/AGR/2024[2014-15]Status: DisposedITAT Agra12 Feb 2025AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri Manoj Kumar Aggarwaldcit, Vs. Gausia Cold Storage Pvt. Ltd. Room No.104, First 304, Gurukrupa, 133, Floor, Aaykar Bhawan, Kazi Sayed Street, Sanjay Place, Agra Maharashtra-400003 /""""""""./Pan/Gir No: Aaacg1215G Appellant .. Respondent Appellant By : Sh. Sukesh Kumar Jain, Cit, Dr Respondent By : Sh. Deependra Mohan, Ca

For Appellant: Sh. Sukesh Kumar Jain, CIT, DRFor Respondent: Sh. Deependra Mohan, CA

Section 143(3)Section 254(1)Section 56(2)Section 56(2)(vii)Section 68

P a g e | 1 Gausua Cold Storage Pvt. Ltd. IN THE INCOME TAX APPELLATE TRIBUNAL “DB” BENCH, AGRA BEFORE

Anand Velumani, Bengaluru vs. Assistant Commissioner of Income Tax, Mumbai

In the result, the appeal filed by the assessee is allowed for statistical purpose

ITA 5339/MUM/2024[2017-2018]Status: DisposedITAT Mumbai08 Jan 2025AY 2017-2018

Bench: MS. KAVITHA RAJAGOPAL (Judicial Member), SHRI. OMKARESHWAR CHIDARA (Accountant Member)

For Appellant: Shri. T. J. PandianFor Respondent: Shri. Ram Krishn Kedia (Sr. DR)

Section 250Section 53Section 56

purchase of a share in the same company in the previous week on 28.02.2017; therefore, the matter fell under the ambit of Section 56 (2)(vii)(c) of the Income Tax Act 1961 according to the AO. The AO and the NFAC failed to appreciate the difference between purchase

Hbs View Private Limited, Mumbai vs. Pr. Commissioner of Income Tax - 8, Mumbai

In the result, appeal of the revenue is dismissed

ITA 2246/MUM/2024[2018-19]Status: DisposedITAT Mumbai01 Jan 2025AY 2018-19

Bench: Shri Narendra Kumar Billaiya, Hon’Ble & Shri Sandeep Singh Karhail, Hon’Ble

For Appellant: Shri Niraj Seth, A/RFor Respondent: Shri Aditya M. Rai, Sr. D/R

Section 24Section 56(2)(vii)

Spl Infrastructure Pvt. Lt, Alwarpet, Chennai vs. ITO, Corporate Circle 6(1), Chennai

ITA 325/CHNY/2023[2018-19]Status: DisposedITAT Chennai29 Nov 2024AY 2018-19

Bench: Shri S.S. Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./I.T.A. No.325/Chny/2023 िनधा"रण वष"/Assessment Year: 2018-19 Spl Infrastructure Pvt. Ltd., Vs. The Income Tax Officer, 15, Kasturi Rangan Road, Corporate Circle – 6(1), Alwarpet, Chennai 600 018. Chennai. [Pan: Aaics0881N] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N. Arjun Raj, Advocate ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/ Date Of Hearing : 08.10.2024 घोषणा की तारीख /Date Of Pronouncement : 29.11.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 06.03.2023 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2018-19. 2. The Assessee Raised 11 Grounds Of Appeal. The Ld. Ar Shri N. Arjun Raj, Advocate, Drew Our Attention To Ground No. 11 & Submits That This Matter Requires To Be Remanded To The File Of The Assessing

For Appellant: Shri N. Arjun Raj, AdvocateFor Respondent: Ms. Gouthami Manivasagam, JCIT

Section 56Section 56(2)(viib)

Rule 11UA(2)(b). During the course of appellate proceedings, the appellant submitted various case laws which is related to section 56(2)(vii)(c) pertaining to Individual and HUF but it is not related to any company, which has independent legal entity and having separate 6 I.T.A. No.325/Chny/23 provision

Sills Karingattil Jose, Nedumkandom vs. ITO Ward 2, Thodupuzha

Appeal is partly allowed for statistical purpose

ITA 132/COCH/2023[2016-17]Status: DisposedITAT Cochin19 Nov 2024AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singhsils Karingattil Jose Income Tax Officer Np 3/406, Karingattil Ward - 2, House, Munnar Road Thodupuzha Vs. Nedumkandom P.O. [Pan: Afopj8789C] (Appellant) (Respondent)

For Appellant: Shri P. M. Veeramani, CAFor Respondent: Smt. V. Swarnalatha, Sr. D.R

Section 2(47)Section 2(47)(V)Section 250Section 50CSection 53ASection 56(2)(vii)

Coming to the assessee’s sole substantive grievance raised herein challenging correctness of both the lower authorities action making Section 56(2)(vii)(c)(ii) addition of Rs.11,67,000/-, in the course of assessment as upheld in the lower appellate discussion, we note that the CIT(A)/NFAC ... light of (2024) 460 ITR 628 (Guj.) PCIT Vs. Jigar Jashwantlal Shah rejecting the Revenue’s identical stand as under: 6. Section 56(2)(vii)(c) of the Act, reads as under: "56. (2) In particular, and without prejudice to the generality of the provisions of sub-section

Krishna Murthy Ella, Hyderabad vs. DCIT-Circle-1(2), Hyderabad

In the result, appeal filed by the assessee is allowed

ITA 585/HYD/2023[2014-15]Status: DisposedITAT Hyderabad14 Aug 2024AY 2014-15

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.585/Hyd/2023 & Sa No.10/Hyd/2024 (Arising Out Of Ita No.585/Hyd/2023) (िनधा"रण वष"/Assessment Year: 2014-15) Shri Krishna Murthy Ella Vs. Dy. C. I. T. Hyderabad Circle 1(2) Pan:Aacpe6389G Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: Smt. Sheetal Sarin, Dr सुनवाई की तारीख/Date Of Hearing: 18/07/2024 घोषणा की तारीख/Pronouncement: 14/08/2024 आदेश/Order

For Appellant: Shri P Murali Mohan Rao, CAFor Respondent: : Smt. Sheetal Sarin, DR

Section 147Section 148Section 56(2)(vii)

Ella consideration which is less than the fair market value/book value, the same needs to be treated as income in terms of section 56(2)(vii)(c) of the I.T. Act, 1961. Therefore, opined that the income chargeable to tax had been escaped the assessment to the tune of Rs.5 ... same was provided to the assessee. The Assessing Officer called upon the assessee to explain as to why the provisions of section 56(2)(vii)(c) of the I.T. Act, 1961 should not be invoked to assess the difference between book value/fair value of the shares as on the date

Peter Andrade (Through Legal Heir), Mumbai vs. Asstt Commissioner of Income Tax, Circle 7(1)(2), Mumbai

In the result, the appeal filed by the assessee is treated as allowed

ITA 1860/MUM/2024[2012-13]Status: DisposedITAT Mumbai04 Jul 2024AY 2012-13

Bench: Shri B.R. Baskaran (Am) & Shri Sunil Kumar Singh (Jm) I.T.A. No. 1860/Mum/2024 (A.Y. 2012-13) Nigel Peter Andrade Vs. Acit, Circle-7(1)(2) (Legal Heir Of Peter Mumbai-400020. Andrade) 204, Sumer Kendra, Pandurag Budhkar Marg, Worli, Mumbai-400018. Pan : Aaapa5059M (Appellant) (Respondent) Assessee By Shri Vijay Mehta Department By Shri H. M. Bhatt (Sr. Dr) Date Of Hearing 25.06.2024 Date Of Pronouncement 04.07.2024 O R D E R Per B.R.Baskaran (Am) :-

Section 56(2)(vii)

IN THE INCOME TAX APPELLATE TRIBUNAL Mumbai “C” Bench, Mumbai. Before Shri B.R. Baskaran (AM) & Shri Sunil Kumar Singh (JM