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“section 56(2)(vii)”

Special Rate ProvisionsSection 56(2)(vii)Section 56(2)(vii)741 judgments

The decision most relied on for section 56(2)(vii) is Rajeev Kumar Agarwal v. ACIT (149 ITD 363), cited in 104 judgments on BharatTax.

Leading authorities on section 56(2)(vii)

Rajeev Kumar Agarwal v. ACIT
149 ITD 363 · 2014 · ITAT
104
citing judgments

Curative amendments, such as a proviso to Section 40(a)(ia) introduced to remove undue hardship, apply retrospectively even without specific legislative declaration, rectifying shortcomings and obviating unintended difficulties.

CIT v. Puneet Sabharwal
338 ITR 485 · 2011 · High Court
69
citing judgments

The revenue must prove that an assessee received extra consideration beyond the declared value; a Departmental Valuation Officer's (DVO) report alone is insufficient to establish such receipt.

CIT v. Mukundray K. Shah, Citation No.
160 Taxmann 276 · 2007 · Supreme Court
39
citing judgments

Section 2(22)(e) of the Income Tax Act, 1961, aims to prevent tax evasion by treating certain payments made by closely held companies to shareholders or their concerns as dividends.

ICDS Ltd. v. CIT
10 SCC 529 · Reported
24
citing judgments

The Supreme Court remands a matter when an assessee is deprived of the opportunity to cross-examine individuals whose statements were relied upon by the Revenue under Section 132(4) of the Income Tax Act.

Ors., 1963 AIR 1526 17. ITO vs. B.N. Bhattacharya, 112 ITR 423 18. R. Dalmia v. CIT (Central)
186 ITR 313 · 1990 · High Court
24
citing judgments

The case addresses the taxability of cash withdrawn from sub-contractors' bank accounts by employees of a civil contractor engaged in infrastructure development. The revenue observed these withdrawals during search proceedings, indicating potential issues with the assessee's tax compliance.

Calcutta in Reliance Jute Industries Ltd. v. Income Tax Officer
150 ITR 643 · 1984 · High Court
23
citing judgments

The Assessing Officer (AO) is not required to refer the valuation to the District Valuation Officer (DVO) if the AO has conducted a detailed inquiry and is satisfied with the cost of construction. Strict adherence to procedural requirements is essential; failure to comply with mandatory conditions renders the assessment based on such non-compliance invalid.

370 ITR 720 (Allahabad) 9. Star Chemical (P.) Ltd. v. CIT
12 Taxmann.com 496 · 2011 · High Court
21
citing judgments

When lending money is not the business of a company, loans or advances given to an assessee-shareholder are treated as deemed dividends under section 2(22)(e) of the Income-tax Act. The provisions of section 2(22)(e) apply to a company that has taken a loan from its subsidiary.

CIT v. Smt Padma S. Bora
54 Taxmann.com 319 · 2015 · High Court
21
citing judgments

A debt written off in the assessee's books as irrecoverable, which was advanced in the ordinary course of business, is allowable as a deduction. The court noted that the Tribunal may have made a mistake in reproducing the Commissioner's findings, but this did not raise a substantial question of law regarding the allowability of bad debts.

Judgments citing section 56(2)(vii)

Devaraya Pillai Subramanian, Salem vs. ITO, Ward-1(1), Salem

In the result, appeal filed by the assessee is allowed

ITA 561/CHNY/2025[2017-18]Status: DisposedITAT Chennai04 Sept 2025AY 2017-18

Bench: Shri George George K & Shri S.R.Raghunathaआयकर अपील सं./Ita No.: 561/Chny/2025 धनिाजरण वर्ज / Assessment Year:2017-18 Devaraya Pillai Subramanian, Ito 58A, Sathyamoorthy Street, Vs. Ward – 1(1), Salem – 636 001. Salem. Tamil Nadu. [Pan: Aijps-3267-J] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) अपीलाथीकीओरसे/Appellant By : Mr. N. Arjun Raj, Advocate प्रत्यथीकीओरसे/Respondent By : Ms. Sita Krishnamoorthy, Jcit

For Appellant: Mr. N. Arjun Raj, AdvocateFor Respondent: Ms. Sita Krishnamoorthy, JCIT
Section 56(2)(viii)

during the year on enhanced compensation u/s.28 of the Land Acquisition Act, 1894 was rightly brought to tax by the AO in invoking Section 56(2)(vii) r.w.s 145B(1) of the Act. 12. The Ld. CIT(Appeals) in the process had also rejected the assessee's claim ... same has filed the present appeal. 14. Before us, the Ld. AR argued that the AO went wrong in invoking the provisions in Section 56(2)(vii) r.w.s 145B() of the Act to the facts and in the circumstances of the present case inasmuch it was argued that interest component

Rahul Rameshchandra Jain, Mumbai vs. ITO Ward 22(3)(6), Mumbai

In the result, ground no. 3 of appeal of assessee is allowed for statistical purpose

ITA 2967/MUM/2025[2017-18]Status: DisposedITAT Mumbai04 Sept 2025AY 2017-18

Bench: Shri Pawan Singh(Physical Hearing) Rahul Rameshchandra Jain Ito, Ward – 22(3)(6), Mumbai 7A/701, Shanti Niketan Chs, Vs Piramal Chamber, Lalbaug, Gandhinagar, Dr. E Moses Road, Mumbai – 400012. Worli, Mumbai – 400018. [Pan: Akgpj2747M] Appellant / Assessee Respondent / Revenue

Section 143(1)Section 147Section 254(1)Section 50CSection 56(2)(vii)Section 69A

assessing officer accepted the report of DVO and accordingly made addition of difference of Rs. 1,12,000/- as deemed income under section 56(2)(vii)(b). 4. The assessing officer further noted that assessee has made cash deposit in ICICI Bank of Rs. 11,30,000/- which ... assessee filed appeal before ld. CIT(A). Before ld. CIT(A), the assessee filed detailed statement of fact. On the addition under section 56(2)(vii)(b), the assessee stated that there difference value declared by assessee and value determined by DVO is less than 10%, therefore, no addition

Suman Jain, Sagar vs. Income Tax Officer Ward-1, Sagar

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

ITA 99/JAB/2024[2017-18]Status: DisposedITAT Jabalpur01 Sept 2025AY 2017-18

Bench: Shri Anadee Nath Misshra

Section 144Section 147Section 249(2)Section 249(3)Section 56(2)(vii)

short) and determined the total income of the assessee at Rs.31,67,705/- by making addition of Rs.28,88,755/- under section 56(2)(vii)(b)(ii) of the Act. Being aggrieved, the assessee filed appeal in the office of learned CIT(A). Vide impugned order dated 22/03/2024, the assessee

Anil Kumar Gupta, Rewa vs. ITO- Ward-1, Rewa

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

ITA 160/JAB/2024[2014-15]Status: DisposedITAT Jabalpur28 Aug 2025AY 2014-15

Bench: Shri Anadee Nath Misshra

Section 144Section 147Section 249(2)Section 249(3)Section 253(3)Section 56(2)(vii)

23/03/2022, determining the total income of the assessee at Rs.6,62,950/- by making addition of Rs.4,70,250/- under section 56(2)(vii)(b) of the Act. Being aggrieved, the assessee filed appeal in the office of learned CIT(A). Vide impugned appellate order dated 09/05/2024, the assessee

Gurmeet Singh, Punjab vs. ITO, Ward-2(2), Ropar, Punjab

In the result, the appeal of the assessee is allowed

ITA 713/CHANDI/2025[2010-11]Status: DisposedITAT Chandigarh27 Aug 2025AY 2010-11

Bench: Shri Laliet Kumarआयकर अपील सं./ Ita No. 713/Chd/2025 "नधा"रण वष" / Assessment Year : 2010-11 Gurmeet Singh, Ito, बनाम 939, Type Ii, Ward 2(2), Nuhon Colony Ghanauli, Ropar Vs. Rupnagar 140113 "थायी लेखा सं./Pan No: Ageps7897P अपीलाथ"/Appellant ""यथ"/Respondent ( Virtual Hearing ) "नधा"रती क" ओर से/Assessee By : Shri. Parikshit Aggarwal,Ca राज"व क" ओर से/ Revenue By : Smt. Surinder Kaur Waraich, Addl. Cit, Sr. Dr सुनवाई क" तार"ख/Date Of Hearing : 27-08-2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 27-08-2025 आदेश/Order

For Appellant: Shri. Parikshit Aggarwal,CAFor Respondent: Smt. Surinder Kaur Waraich, Addl. CIT
Section 147Section 271(1)(c)Section 56Section 56(2)(vii)

under the head “Income from other sources,” on the ground that cousins do not fall within the definition of “relative” as provided in section 56(2)(vii) of the Act. The penalty proceedings u/s 271(1)(c) were thereafter initiated and penalty of ₹97,743/- was levied on the assessee ... gifts in question were received from cousins and that such relations do not fall in the definition of “relative” as envisaged under section 56(2)(vii) of the Act. However, the surrounding circumstances show that the assessee, being an agriculturist with limited exposure to legal provisions, acted under a bona

Gurmeet Singh, Punjab vs. ITO, Ward-2(2), Ropar, Punjab

In the result, the appeal of the assessee is dismissed

ITA 712/CHANDI/2025[2010-11]Status: DisposedITAT Chandigarh27 Aug 2025AY 2010-11

Bench: Shri Laliet Kumarआयकर अपील सं./ Ita No. 712/Chd/2025 "नधा"रण वष" / Assessment Year : 2010-11 Gurmeet Singh, Ito, बनाम 939, Type Ii, Ward 2(2), Nuhon Colony Ghanauli, Ropar Vs. Rupnagar 140113 "थायी लेखा सं./Pan No: Ageps7897P अपीलाथ"/Appellant ""यथ"/Respondent ( Virtual Hearing ) "नधा"रती क" ओर से/Assessee By : Shri. Parikshit Aggarwal, Ca राज"व क" ओर से/ Revenue By : Smt. Surinder Kaur Waraich, Addl. Cit, Sr. Dr सुनवाई क" तार"ख/Date Of Hearing : 27-08-2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 27-08-2025 आदेश/Order

For Appellant: Shri. Parikshit Aggarwal, CAFor Respondent: Smt. Surinder Kaur Waraich, Addl. CIT
Section 147Section 56Section 56(2)(vii)

Singh and Shri Nirmal Singh. The Assessing Officer held that these persons do not fall within the definition of “relative” as given in section 56(2)(vii) of the Act. Consequently, the amount of ₹3,00,000/- was treated as income from other sources and added to the total income ... hand, strongly relied upon the orders of the lower authorities and submitted that the statute has provided an exhaustive definition of “relative” in section 56(2)(vii) and cousins are not included therein. Hence, the addition has rightly been made and sustained. 9. I have considered the rival submissions

Nibedita Deb Barma, Kolkata vs. ITO, Ward 60(2), Kolkata

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

ITA 578/KOL/2025[2016-2017]Status: DisposedITAT Kolkata27 Aug 2025AY 2016-2017

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 578/Kol/2025 Assessment Year: 2016-2017 Nibedita Deb Barma,……………….…………..…Appellant 30/7B, Doctor Lane, Taltala, Kolkata-700014 [Pan:Adipd1863D] -Vs.- Income Tax Officer,…………………..…………..Respondent Ward-60(2), Kolkata, 169, A.J.C. Bose Road, Bamboo Villa, Kolkata-700014 Appearances By: Shri Ankit Jalan, A.R., Appeared On Behalf Of The Assessee Shri Susanta Saha, Sr. D.R., Addl. Cit, Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: June 25, 2025 Date Of Pronouncing The Order: August 27, 2025 O R D E R

Section 142(1)Section 142(2)Section 143(3)Section 271(1)(b)Section 56(2)(vii)Section 69

Being aggrieved, the assessee preferred an appeal before the ld. CIT(Appeals). The ld. Addl./JCIT(Appeals) firstly reduced the addition under section 56(2)(vii)(b) from Rs.8,14,164/- as made by the ld. Assessing Officer in the assessment order to Rs.1,23,156/- 2 Nibedita Deb Barma ... market value for stamp duty purposes was lower than initially estimated, therefore, the difference of Rs.1,23,156/- remained the taxable amount under section 56(2)(vii)(b). Ld. Addl./JCIT(Appeals) was of the view that the provision explicitly states that where the stamp duty value of a property

DCIT, CC-30, New Delhi vs. Rajan Sharma, New Delhi

ITA 2441/DEL/2022[2017-18]Status: DisposedITAT Delhi27 Aug 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 1Section 143(3)Section 153A

assessee's hands. 17. Suffice to say, it could hardly be disputed that be it u/s 50C or 43CA or Section 56(2)(vii) applicable in cases of capital gains arising from sale/transfer of a capital asset, business income arising from sale or transfer of the specified assets

DCIT, Central Circle-30, New Delhi vs. Rajan Sharma, Delhi

ITA 2120/DEL/2022[2015-16]Status: DisposedITAT Delhi27 Aug 2025AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 1Section 143(3)Section 153A

assessee's hands. 17. Suffice to say, it could hardly be disputed that be it u/s 50C or 43CA or Section 56(2)(vii) applicable in cases of capital gains arising from sale/transfer of a capital asset, business income arising from sale or transfer of the specified assets

DCIT, Central Circle-30, New Delhi vs. Rajan Sharma, Delhi

ITA 2119/DEL/2022[2014-15]Status: DisposedITAT Delhi27 Aug 2025AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 1Section 143(3)Section 153A

assessee's hands. 17. Suffice to say, it could hardly be disputed that be it u/s 50C or 43CA or Section 56(2)(vii) applicable in cases of capital gains arising from sale/transfer of a capital asset, business income arising from sale or transfer of the specified assets

DCIT, Central Circle-30, New Delhi vs. Rajan Sharma, Delhi

ITA 2118/DEL/2022[2013-14]Status: DisposedITAT Delhi27 Aug 2025AY 2013-14

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 1Section 143(3)Section 153A

assessee's hands. 17. Suffice to say, it could hardly be disputed that be it u/s 50C or 43CA or Section 56(2)(vii) applicable in cases of capital gains arising from sale/transfer of a capital asset, business income arising from sale or transfer of the specified assets

DCIT Central Circle-30, New Delhi vs. Rajan Sharma, Delhi

ITA 2117/DEL/2022[2012-13]Status: DisposedITAT Delhi27 Aug 2025AY 2012-13

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 1Section 143(3)Section 153A

assessee's hands. 17. Suffice to say, it could hardly be disputed that be it u/s 50C or 43CA or Section 56(2)(vii) applicable in cases of capital gains arising from sale/transfer of a capital asset, business income arising from sale or transfer of the specified assets

Savaligayya Basayya Gaddagimath, Dharwad vs. ITO, Ward 1(1), Hubli

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

ITA 1011/BANG/2025[2017-18]Status: DisposedITAT Bangalore26 Aug 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2017-18

For Appellant: Shri Deepak Gunashekhar, ARFor Respondent: Shri Ganesh R Ghale, Standing Counsel for Department
Section 133(6)Section 148Section 56(2)(vii)

2. The issue raised by the assessee is that the learned NFAC/CIT(A) erred in confirming the addition of Rs. 4.5 lakh under section 56(2)(vii)(b)(ii) of the Act. Page 2 of 8 3. The relevant facts are that the assessee is an individual and 76 years ... opinion that the difference between stamp value and actual consideration was liable to tax under the provision of section 56(2)(vii)(b)(ii) of the Act, but the assessee has not filed return of income, and the income escaped assessment. Accordingly, the assessment was reopened. 5. During the assessment

Mr. Dilip Marutirao Kalyankar, Mumbai vs. Income Tax Officer International Taxation Ward 3(1)(1), Mumbai

In the result, the appeal is allowed as indicated above

ITA 983/MUM/2025[2016-17]Status: DisposedITAT Mumbai25 Aug 2025AY 2016-17

Bench: Shri Saktijit Dey, Vp & Shri Girish Agrawal, Am Dilip Marutirao Kalyankar Ito, International Taxation – C/O. Umesh Kalyankar, 2F-1501, 3(1)(1) Room No. 608, 6Th Floor, Sapphire Lakeside Chs, Vs. Off Jvlr, Next To Union Of India Kautilya Bhavan, C-41 To C-43, Bldg., Powai, Mumbai-400 072 G Block, Bandra Kurla Complex, Bandra (E), Mumbai-400 051 Pan/Gir No. Ahopk 3818 M (Appellant) : (Respondent)

For Appellant: Shri Madhur Agrawal &For Respondent: Shri Krishna Kumar (Sr. DR)
Section 139(1)Section 147Section 148Section 69

Stamp Valuation Authority determined the value of the property at Rs.1,92,73,500/- for stamp duty purpose. Invoking the provision of section 56(2)(vii)(b) of the Act, the A.O. treated the value determined by the Stamp Valuation Authority as deemed sale consideration paid by the assessee ... course of remand proceeding. After verifying the evidences furnished by the assessee, the A.O. has commented as under: III. ADDITION UNDER SECTION 56(2) (vii)(b): The applicant had stated that the AO has made an addition of Rs.46,54,986/-under section 56(2)(vii

Assistant Commissioner of Income Tax, Kalyan vs. Chander Arjandas Manwani, Ulhasnagar

In the result, the appeal filed by the Revenue fails and is

ITA 2733/MUM/2025[2018-19]Status: DisposedITAT Mumbai25 Aug 2025AY 2018-19

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: Shri Shashank MehtaFor Respondent: Mr. Virabhadra S. Mahajan, Sr.DR
Section 143(3)Section 22Section 56(2)(vii)Section 68

family members, whose relationship with the assessee stood clearly established and, indeed, fell squarely within the statutory definition of “relative” as contemplated under section 56(2)(vii) of the Act. The particulars of such family members, together with the quantum of gifts received from each, were placed before the Assessing

ACIT Central Circle-1, Faridabad vs. Sohan Lal Singla, New Delhi

Appeal is dismissed

ITA 8433/DEL/2019[2012-13]Status: DisposedITAT Delhi25 Aug 2025AY 2012-13

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwalita No. 8433/Del/2019 : Asstt. Year : 2012-13 Acit, Vs Sohan Lal Singla, Central Circle-1, 31, Punjabi Bagh, West Avenue, Faridabad, Haryana-121001 New Delhi-121001 (Appellant) (Respondent) Pan No. Aezps1205E Assessee By : Sh. G. C. Srivastava, Adv. & Sh. Kalrav Malhotra, Adv. Revenue By : Ms. Monika Singh, Cit-Dr Date Of Hearing: 17.07.2025 Date Of Pronouncement: 25.08.2025 Order Per Satbeer Singh Godara: This Revenue’S Appeal For Assessment Year 2012-13, Arises Against The Cit(A)-3, Gurgaon’S In Case No. 347/Cit(A)- 3/Ggn/2017-18 Dated 14.08.2019, In Proceedings U/S 153A Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. G. C. Srivastava, Adv. &For Respondent: Ms. Monika Singh, CIT-DR
Section 153ASection 56(2)(vii)

assessment order?” 4. Suffice to say, the Revenue’s sole endavour herein is to revive the Assessing Officer’s action making section 56(2)(vii)(c) addition of Rs.6,87,75,000/- thereby holding the assessee’s share premium received at a heavy discount price of Rs.10.- against fair market

Subir Mandal, Jamshedpur vs. ITO Ward 3(4), Chaibasa, Jamshedpur

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

ITA 188/RAN/2025[2017-18]Status: DisposedITAT Ranchi22 Aug 2025AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Ratnesh Nandan Sahayi.T.A. No. 188/Ran/2025 Assessment Year: 2017-2018 Subir Mandal,….…………………………………..Appellant 61, Parsudih, Pramathanagar, Jamshedpur-831001, Jharkhand [Pan:Anfpm1717N] -Vs.- Income Tax Officer,……………………………...Respondent Ward-3(4), Chaibasa, 47, Ch Area, Jamshedpur-831001, Jharkhand Appearances By: Shri Akshay Ringasia, A.R., Appeared On Behalf Of The Assessee Shri Khubchand T. Pandya, Sr. D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: July 21, 2025 Date Of Pronouncing The Order: August 25, 2025 O R D E R

Section 142(1)Section 143(1)Section 148Section 56(2)(vii)

ITA No. 188/RAN/2025 (A.Y. 2017-2018) Subir Mandal IN THE INCOME TAX APPELLATE TRIBUNAL, KOLKATA-RANCHI ‘e-COURT’, KOLKATA [Hybrid

Gummadi Saraswathi, Tenali vs. Income Tax Officer, Ward-1, Tenali

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

ITA 375/VIZ/2025[2016-17]Status: DisposedITAT Visakhapatnam20 Aug 2025AY 2016-17

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआईटीए. नं. / Ita No. 375/Viz/2025 (A.Y. 2016-17) Gummadi Saraswathi V. Income Tax Officer - Ward – 1 C/O. Ca Mv Prasad Income Tax Office First Floor D.No. 19-15-47 Opposite Prasad & Co Contractors Opp. Sai Baba Temple D.No. 6-3-871, Snehalata Tenali – 522201 Greenlands Road, Begumpet Andhra Pradesh Hyderabad – 500016 [Pan:Amapg7100K] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

Section 147Section 263Section 56(2)(vii)

stamp duty value of the property over the purchase consideration i.e. Rs.18,76,500/- and treated as undeclared income from other sources under section 56(2)(vii) of the Act. 5. Aggrieved by the order of the Ld. AO, assessee filed an appeal before

Atar Singh, Delhi vs. ITO, Ward 70 (1)-Delhi, Delhi

ITA 186/DEL/2025[2017-18]Status: DisposedITAT Delhi20 Aug 2025AY 2017-18

Bench: Shri M. Balaganesh

For Appellant: Mr. R. Sahu, CAFor Respondent: Shri Manoj Kumar, Sr. DR
Section 115BSection 142(1)Section 147Section 148Section 151ASection 282Section 56(2)Section 56(2)(vii)Section 69A

erred in not referring the matter to DVO for valuation of the immovable property as specified in the Proviso 3 of the section 56(2) (vii) clause (b), even though the assessee is insisting that immovable property was purchased as per the market rate prevailing in the locality where

Luxeva India Private Limited, Maharashtra vs. NFAC, Delhi

Appeal is allowed with aforesaid consequences to follow

ITA 4495/DEL/2024[2018-19]Status: DisposedITAT Delhi20 Aug 2025AY 2018-19

Bench: SHRI S. RIFAUR RAHMAN (Accountant Member), SHRI ANUBHAV SHARMA (Judicial Member)

For Appellant: Ms Neha Vikram, CA &For Respondent: Ms Amisha s. Gupt, CIT-DR
Section 142(1)Section 143(3)Section 56Section 56(2)(vii)Section 56(2)(viib)

Rs.19,88,850/-. But the company raised share premium of Rs.13,96,79,002/-. The AO noted that this attracts the provisions of section 56(2)(vii)(b) of the Act and accordingly, the AO completed the assessment proceedings thereby making addition of Rs.13,76,90,152/- (Rs.13 ... bench decision in ITA No. 1526/Del/2022 M/s.Planet Gogo Pvt. Ltd., Vs. ITO, Ward-3(2), Gurgaon order dated 24.02.23. Thus, the provisions of section 56(2)(vii)(b) of the Act have been erroneously invoked. Ground no. 1 to 3 are sustained. Impugned addition is deleted. 6. As with regard