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“Section 56(2)”

Section References (mined)Section 56Section 56(2)1,770 judgments

The decision most relied on for Section 56(2) is Totgars Co-operative Sale Society Ltd. v. ITO (322 ITR 283), cited in 1,283 judgments on BharatTax.

Leading authorities on Section 56(2)

Totgars Co-operative Sale Society Ltd. v. ITO
322 ITR 283 · 2010 · Supreme Court
1,283
citing judgments

The interest income earned by a cooperative society from investing its surplus funds in fixed deposits with banks is not "derived from" its eligible business activities and is taxable as "income from other sources" under Section 56, thus not qualifying for deduction under Section 80P.

Pr. CIT v. Totagars
395 ITR 611 · 2017 · High Court
1,074
citing judgments

Interest income earned by a cooperative society from surplus deposits or investments held with a cooperative bank is not eligible for deduction under Section 80P(2)(d) of the Act.

Mavilayi Service Co-operative Bank Ltd. v. CIT
431 ITR 1 · 2021 · Supreme Court
999
citing judgments

Section 80P(4) serves as a proviso to Section 80P(1) and (2), excluding only cooperative banks that are cooperative societies and possess an RBI license for banking business. Its purpose is to exclude cooperative banks operating like commercial banks that lend money to the public.

CIT v. Sunbeam Auto Ltd.
332 ITR 167 · 2011 · High Court
897
citing judgments

The Commissioner cannot revise an assessment under Section 263 merely because the assessment order does not explicitly reflect an inquiry, or because the Commissioner holds a different opinion. An inquiry, even if considered inadequate, or an assessment based on a plausible view by the Assessing Officer after due examination, does not automatically make the order erroneous or prejudicial to the interests of the revenue.

Tumkur Merchants Souharda Credit Cooperative Ltd. v. ITO
230 Taxmann 309 · 2015 · High Court
527
citing judgments

A cooperative society is eligible for deduction under Section 80P(2)(a)(i) if it is engaged in cooperative activities. It also clarifies the allowability of deduction under Section 80P(2)(d) for interest income received from investments made in cooperative banks, after duly considering the Supreme Court's decision in Totgars Co-operative Sale Society Ltd.

Citizen Co-operative Society Ltd. v. ACIT
397 ITR 1 · 2017 · Supreme Court
499
citing judgments

A co-operative credit society engaged in banking business with the general public, accepting deposits from non-members and advancing loans to non-members, is treated as a co-operative bank. Such a society falls under the exclusionary clause of Section 80P(4) and is not eligible for deduction under Section 80P(2)(a)(i).

Totgar's Co-operative Sale Society Ltd. v. ITO
188 Taxmann 282 · 2010 · Supreme Court
486
citing judgments

Interest income earned by a co-operative society from investments, particularly with co-operative banks, is not eligible for deduction under Section 80P as it is not attributable to the core business activities of the society and constitutes "other income", not "profits and gains of business".

ITO v. D.G. Housing Projects Ltd.
343 ITR 329 · 2012 · High Court
438
citing judgments

For exercising revisional jurisdiction under Section 263, the Commissioner must first find that the Assessing Officer's order is erroneous and unsustainable in law, as this is a condition precedent. An order is not erroneous merely because two views are possible, or if the Commissioner disagrees with the Assessing Officer's permissible view, or to simply remit the matter for further enquiries.

Judgments citing Section 56(2)

Mr. Thirumani, Chennai vs. ACIT, Ncc-6(1), Chennai

In the result, the appeal of the assessee is allowed

ITA 3351/CHNY/2024[2016-17]Status: DisposedITAT Chennai05 Jan 2026AY 2016-17

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:3351/Chny/2024 िनधा$रण वष$ / Assessment Year: 2016-17 Thirumani, Acit, 260/1, Mint Street, Park Town, Vs. Non-Corporate Circle 6(1), Chennai – 600 003. Chennai – 600 034. [Pan: Aagpt-7541-K] (अपीलाथ&/Appellant) ('(थ&/Respondent)

For Appellant: Shri. B. Ramakrishnan, F.C.AFor Respondent: Ms. Gouthami Manivasagam, J.C.I.T
Section 142(1)Section 143(2)Section 143(3)Section 54Section 54FSection 56(2)(vii)

reliance on the much higher guideline value. Thus, the very foundation of the original addition stands substantially eroded. 26. We note that Section 56(2)(vii)(b) is a deeming provision, intended to tax real income arising from understatement of consideration. Such provisions must be strictly construed and cannot

Jagmeet Singh Sabharwal, Mumbai vs. Commissioner of Income Tax, Income Tax

The appeal of the assessee is allowed

ITA 954/MUM/2025[2012-13]Status: DisposedITAT Mumbai05 Jan 2026AY 2012-13

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Shri Surendra Singh Sabharwal, ARFor Respondent: Ms. Kavitha Kaushik (Sr. DR)
Section 143(3)Section 2(47)Section 50C

third proviso of section 50C(1) providing exception in case of difference in value is less than 10% would be applicable to section 56(2)(vii)(b) has been discussed at length including the amendment brought in by the Finance Act 2018 and it has been held that section 56 ... construed alongwith sections 50C, 56(2)(x) and 43CA and the exceptions provided in the later three provisions have to be read _ into section 56(2)(vii)(b)(ii) to provide true meaning to the intention of the legislature and it has been held that the assessee would be eligible

Lakhi Ram, Gurugram vs. ITO Ward 1(4) Gurgaon, Gurugram

In the result, appeal of the assessee is allowed

ITA 2028/DEL/2024[2019-20]Status: DisposedITAT Delhi05 Jan 2026AY 2019-20

Bench: Sh. Satbeer Singh Godara & Sh. Amitabh Shuklaita No. 2028/Del/2024 : Asstt. Year: 2019-20 Lakhi Ram, Vs Income Tax Officer, House No. 70, Village- Dhanwapur, Ward-1(4), Daultabad, Gurugram, Gurugram, Haryana-122001 Haryana-122001 (Appellant) (Respondent) Pan No. Awzpr6814L Assessee By : None Revenue By : Ms. Ankush Kalra, Sr. Dr Date Of Hearing: 05.01.2026 Date Of Pronouncement: 05.01.2026 Order Per Satbeer Singh Godara: This Assessee’S Appeal For Assessment Year 2019-20 Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2023-24/1061566876(1) Dated 27.02.2024, In Proceedings U/S 144 R.W.S. 142(1) Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: NoneFor Respondent: Ms. Ankush Kalra, Sr. DR
Section 10(37)Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 144Section 263Section 28Section 56(2)(viii)

Ghanshyam HUF dated 16th July, 2009 relating to the taxability of interest received on compensation or enhanced compensation and also the amendments/provisions of section 56(2)(viii) introduced through Finance Act, 2009 effective from 01.04.2010 on the above issue, which the Ld. AO failed to do. The Ld. PCIT pointed ... audit objection observing that interest under section 28 of Land Acquisition Act of Rs. 3,97,56,460/- was chargeable to tax under section 56(2)(viii) of the Act and also referred to the decisions in the cases of Shri Manjeet Singh HUF v. UOI & Others

Madhur Coal Mining Pvt. Ltd., Kolkata vs. D.C.I.T., Circle - 8(1), Kolkata

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

ITA 1784/KOL/2025[2015-2016]Status: DisposedITAT Kolkata02 Jan 2026AY 2015-2016

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 143(2)Section 143(3)Section 250Section 50DSection 56(2)(viia)

Appeals), NFAC was wrong in upholding the addition of Rs.13,23,01,000 made by the Assessing Officer by applying the provisions of Section 56(2)(viia) in the matter of Shares acquired by the appellant on allotment of the Shares by subscribing thereto. (2) That without prejudice ... contention raised in Ground No. (1) above, the Ld. Commissioner of Income-tax (Appeals), NFAC failed to appreciate that the provisions of Section 56(2)(viia) could not be applied in the case of a direct allotment of Shares by a company and thus the Ld. Commissioner of Income

G.S. Procon Private Limited, Kolkata vs. ACIT, Circle 5(2), Kolkata

In the result, appeal of the assessee is allowed

ITA 509/KOL/2025[2015-2016]Status: DisposedITAT Kolkata01 Jan 2026AY 2015-2016

Bench: SHRI GEORGE MATHAN (Judicial Member), SHRI RAJESH KUMAR (Accountant Member)

For Respondent: Shri Bonnie Deb Barma, Sr. DR
Section 56(2)(vii)

that the assessee is in the business of civil contractor. In the course of assessment, the Assessing Officer had invoked the provisions of Section 56(2)(vii)(b)(i) of the Act (wrongly mentioned by the Assessing Officer as 56(1)(vii)(b)(i)) and had disallowed the difference between ... also recognised as a company in the assessment order in column 5 of the status. It was the submission that the provision of Section 56(2)(vii)(b)(i) of the Act applies to an individual or HUF. It was the submission that the assessee being not an individual

Dhruti Jaysukhbhai Ranpariya, Jamnagar vs. The ITO Ward-2 (6) Jamnagar, Jamnagar

In the result, appeal filed by the assessee is allowed

ITA 536/RJT/2025[2018-19]Status: DisposedITAT Rajkot31 Dec 2025AY 2018-19

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./ Ita No. 536/Rjt/2025 Assessment Year: 2018-19 Dhruti Jaysukhbhai Ranpariya Income Tax Officer, Ward-2(6), बनाम/ Dhareshwar Appartment 56, Jamnagar, Aaykar Bhawan, 4Th Digvijay Plot, Floor, Manek Center, Nehru Road, Vs. Jamnagar (Guj) -361005 Jamnagar (Guj) -361006 "थायीलेखासं/.जीआइआरसं./ Pan/Gir No.: Aqkpr6633C : (अपीलाथ"/Assessee) (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Hardik Vora, Ar राज"व क" ओर से/ Revenue By : Shri Abhimanyu Singh Yadav, Sr-Dr सुनवाई क" तार"ख/Date Of Hearing : 16/12/2025 घोषणा क" तार"ख/Date Of Pronouncement : 31/12/2025

For Appellant: Shri Hardik Vora, ARFor Respondent: Shri Abhimanyu Singh Yadav, Sr-DR
Section 142(1)Section 143(2)Section 250Section 44ASection 69A

Therefore, we note that aforesaid gifts squarely fall within the exemption of section56(2)(x) of the Act. The provisions of section 56(2)(x) of the Act, are reproduced below, for ready reference as follows: “(x) where any person receives, in any previous year, from any person or persons ... gift. It is a gift received from relative mentioned in the above section. This is a category of transfer under Section 56(2)(x) of the Act which are, from the plan language of the statute not taxable and hence no addition can be made in the hands

Mrs. Deepali Vikki Ajmera, Mulund vs. ITO Ward 27(1)(1), Mumbai, Navi Mumbai

In the result, appeal filed by the Assessee is allowed

ITA 4981/MUM/2025[2020-21]Status: DisposedITAT Mumbai30 Dec 2025AY 2020-21

Bench: Shri Narender Kumar Choudhryassessment Year: 2020-21 Mrs. Deepali Vikki Ajmera, Ito Ward 27 (1) (1), 5Th Floor, Prem Ratna Building, Tower 6, Vashi Station Ambedkar, Road Opp. Balaji Vs. Complex, Navi Mumbai – Temple, Mulund West, Mumbai 400703. – 400080. Pan – Agvps 7279 Q (Appellant) (Respondent) Present For: Assessee By : Shri Piyush Bafna, Ca (Virtually Appear) Revenue By : Shri A.M.K. Mahadevan, Sr. D.R. Date Of Hearing : 19.11.2025 Date Of Pronouncement : 30.12.2025 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 30.08.2024, Impugned Herein, Passed By The National Faceless Appeal Centre (Nfac)/Ld. Commissioner Of Income Tax (Appeals) (In Short Ld. Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2020-21. 2. At The Outset, It Is Observed That There Is A Delay Of 281 Days In Filing The Instant Appeal, On Which The Assessee Has Claimed As Under :- Affidavit For Condonation Of Delay 1, Mrs. Deepali Vikki Ajmera, Age About 45 Years, Residing At 5Th Floor, Prem Ratna Building, Ambedkar Road, Opp Balaji Temple

For Appellant: Shri Piyush Bafna, CAFor Respondent: Shri A.M.K. Mahadevan, SR. D.R
Section 250

difference between stamp value & purchase value)] as per Agreement of sale submitted by the Assessee and also as per the provisions of section 56(2)(x) as discussed above. 9.1 The AO ultimately, held the differential amount of Rs. 75,05,715/- between the stamp duty value and purchase valuation ... deemed income under Section 56 (2) (x) of the Act, which works out to Rs. 25,01,905/- being 1/3rd in the hands of the Assessee and consequently added to the total income of the Assessee. 9.2 Further, the AO also treated the amount of Rs.20,50,325/- as unexplained

Rekha Kishore Shah (Legal Heir of Kishor Dhirajlal Shah ), Mumbai vs. ACIT-42(1)(1), Mumbai

ITA 4409/MUM/2025[2017-18]Status: DisposedITAT Mumbai30 Dec 2025AY 2017-18

Bench: Shri Amit Shukla, Jm & Shri Arun Khodpia, Am

For Appellant: Shri Malav P. ShethFor Respondent: Assessee by
Section 147Section 148ASection 250Section 56(2)Section 56(2)(vii)

whereas the agreement of sale and registration was done on 31-03-2017. Thus the learned AO erred in applying the provisions of section 56(2)(vii) (b) to AY 2017-18 instead in AY 2012-13 without appreciating the proviso to the said section. Thus additions made

Meena Arjun Narang, Mumbai vs. ACIT, Circle 27(2), Mumbai

In the result, the appeal of the assessee is allowed

ITA 6651/MUM/2025[2018-19]Status: DisposedITAT Mumbai24 Dec 2025AY 2018-19

Bench: Shri Amit Shukla, Jm & Shri Arun Khodpia, Am

For Appellant: Shri Dhaval Shah, ARFor Respondent: Assessee by
Section 147Section 56(2)(x)

Learned Commissioner of Income Tax (Appeals) ["CIT(A)"] has erred in upholding the validity of reopening of assessment. 2. Erroneous Addition under Section 56(2)(x) On the facts and in the circumstances of the case and in law, the Learned CIT(A) has erred in upholding the addition ... made by the Assessing Officer ("AO") under the head "Income from Other Sources" in terms of section 56(2)(x)(b) of the Income-tax Act, 1961 ("the Act"), in respect of the difference between the agreement value and the stamp duty value of the property, without appreciating the true

Amarjit Kaur Ranjit Singh Anand, Mumbai vs. Deputy Commissioner of Income Tax 24(1), Mumbai

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

ITA 4377/MUM/2025[2018-19]Status: DisposedITAT Mumbai24 Dec 2025AY 2018-19

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2018-19

For Appellant: Mr. Pratik JainFor Respondent: 30/09/2025
Section 250Section 56(2)(x)

difference between the stamp duty value and the stated stamp duty value and the stated consideration as income under consideration as income under section 56(2)(x) of the Act. section 56(2)(x) of the Act. 6.1 The assessee contended before the Assessing Officer that the The assessee contended ... submitted that in terms of the first proviso to section 2017. It was submitted that in terms of the first proviso to section 56(2)(x), the stamp duty value as on the date of agreement ought to 56(2)(x), the stamp duty value as on the date

Faisal Abdul Majeed Kazi, Mumbai vs. Income Tax Offcier 24(1)(1), Piramal Chamber

In the result, assessee‟s appeal is allowed

ITA 3790/MUM/2024[2012-13]Status: DisposedITAT Mumbai24 Dec 2025AY 2012-13

Bench: Shri Narender Kumar Choudhry (Jm) & Shri Prabhash Shankar (Am) Faisal Abdul Majeed Kazi Ito-24(1)(1) E-651, B Wing, 6Th Floor Room No. 702 New Chandra Chsl, Veera Desai Road, Vs. Piramal Chambers Andheri West Lalbaug, Parel Mumbai-400 053 Mumbai-400 051. Pan : Amypk5431D Appellant Respondent Assessee By : Shri Satyaprakash Singh, Ld. Ca Revenue By : Ms. Kavitha Kaushik, Ld Dr Date Of Hearing : 06 /11/2025 Date Of : 24/12/2025 Pronouncement O R D E R Per Narender Kumar Choudhry (Jm) :-

For Appellant: Shri Satyaprakash Singh, LdFor Respondent: Ms. Kavitha Kaushik, Ld DR
Section 143(2)Section 144Section 147Section 148Section 150Section 250Section 56(2)(x)Section 68Section 69Section 80C

Officer did not dispute or mention any word. 8. The Ld. Commissioner though considered the aforesaid remand report and found that provisions of section 56(2)(x) of the Act is not applicable in the case of the assessee, because this particular section has been introduced to the Income

Ish Bhatia, Delhi vs. ITO, Delhi

Appeal is allowed

ITA 7610/DEL/2025[2017-18]Status: DisposedITAT Delhi24 Dec 2025AY 2017-18

Bench: Sh. Satbeer Singh Godaraita No. 7610/Del/2025 : Asstt. Year: 2017-18 Ish Bhatia, Vs Income Tax Officer, 2770/5, Chuna Mandi Pahar Ganj, Ward-62(1), New Delhi-110055 New Delhi-110002 (Appellant) (Respondent) Pan No. Afcpb4844A Assessee By: Sh. Raghav Sharma, Ca & Sh. Mohit Gupta, Ca Revenue By : Sh. Amit Shukla, Sr. Dr Date Of Hearing: 24.12.2025 Date Of Pronouncement: 24.12.2025 Order This Assessee’S Appeal For Assessment Year 2017-18 Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2025-26/10758867882(1) Dated 29.04.2025, In Proceedings U/S 147 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Raghav Sharma, CA &For Respondent: Sh. Amit Shukla, Sr. DR
Section 147Section 56(2)Section 56(2)(x)

parties at length. Case file perused. 3. It emerges during the course of hearing that both the learned lower authorities have invoked section 56(2)(x) of the Act to add the difference between the assessee’s actual purchase price of Rs.9,00,000/- and stamp value of the relevant ... Bhatia 4. That being the case, the Revenue could hardly dispute the clinching fact that the legislature has inserted clause (x) in section 56(2) in the Act vide Finance Act 2017 w.e.f. 01.04.2017 without any retrospective effect as per the relevant Explanatory Memorandum’s clause 33.6 thereto

Himanshu Kukreja, Dehradun vs. ITO, Dehradun

In the result, Appeal of the Assessee is dismissed

ITA 147/DDN/2024[2016-17]Status: DisposedITAT Dehradun23 Dec 2025AY 2016-17

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Himanshu Kukreja Vs Income Tax Officer Matta Garg & Co. Ca 15- Income Tax Office, 13-A, Astley Hall, Dehradun, Subhash Road, Dehradun, Uttarakhand Uttarakjhand Pan:Ahipk9462F Appellant Respondent Assessee By Sh. S. K. Matta, Ca Revenue By Sh. A. S. Rana, Sr. Dr Date Of Hearing 12/11/2025 Date Of Pronouncement 23/12/2025

Section 13(1)Section 143(3)Section 144BSection 263Section 56(2)Section 56(2)(vii)

consideration and hence the value of property including stamp duty should have been considered assessee's income in view of provisions of section 56(2) of the Act. (v) The A.O. has not considered that fact that the assessee is an individual and a separate person and the investment ... Kulwant Kukreja Education Society, Dehradun, found that, the properties in question have been purchased by the Assessee without consideration.Therefore, applied the provisions of Section 56(2)(vii)(b) Act against the Assessee and made addition of Rs. 8,64,15,000/-. 7. During the appellate proceeding

Deputy Commissioner of Income-Tax, Central Circle-1, Surat, Aayakar Bhawan, Majura Gate vs. Royal Developers, Nr. Ip Mission School, Muglisa

ITA 860/SRT/2024[2018-19]Status: DisposedITAT Surat23 Dec 2025AY 2018-19
For Appellant: Mr. Suresh K KabraFor Respondent: Shri Ajay Uke, Sr. DR
Section 143(3)Section 56(2)(x)Section 69Section 69A

assessment order passed under section 143(3) dated 25.09.2021, the Assessing Officer also adverted to the applicability of section 56(2)(x) of the Act, though no separate addition was made thereunder since the entire stamp duty value had already been brought to tax under section 69. 3. On appeal ... Income-tax (Appeals) deleted the addition made under section 69 of the Act. However, no independent finding was recorded on the applicability of section 56(2)(x) of the Act. The Ld. CIT(A) has deleted the addition observing as under: “6. In Ground No.1, 2 and 3, the appellant

Sh. Amrish Singh, Sirsa vs. ACIT/DCIT- Int. Tax, Gurgaon

In the result, appeal of the assessee is allowed

ITA 590/CHANDI/2022[2019-20]Status: DisposedITAT Chandigarh23 Dec 2025AY 2019-20

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2018-19 Shri Karan Jeet Singh, Vs. Dcit/Acit, 1, Hisar Road, Vpo- Intl. Taxation, Khairpur, Ward-4, Sirsa, Gurgaon Haryana Pan: Acgps7292E (Appellant) (Respondent) With Assessment Year: 2018-19 Shri Kabal Jeet Singh, Vs. Dcit/Acit, 1, Hisar Road, Vpo- Intl. Taxation, Khairpur, Ward-4, Sirsa, Gurgaon Haryana Pan: Acgps7934M (Appellant) (Respondent) With Ita Nos.390/Chandi/2021 & 590/Chandi/2022 Assessment Year: 2018-19 & 2019-20 Shri Amrish Singh, Vs. Dcit/Acit, 1, Hisar Road, Vpo- Intl. Taxation, Khairpur, Ward-4, Sirsa, Gurgaon Haryana Pan: Aszps6911K (Appellant) (Respondent) Assessee By Sh. Lalit Mohan, Adv. Sh. Ankit Kumar, Adv. Department By Sh. Mahesh Kumar, Cit(Dr) Date Of Hearing 23.12.2025 Date Of Pronouncement 23.12.2025

Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 263Section 28Section 56(2)(vii)

amounting to Rs.89,16,548/-, Rs.89,16,548/-, Rs.1,69,63,466/- and Rs.39,46,904/-, appeal-wise, respectively, taxed under section 56(2)(vii) r.w.s. 57(iv) of the Act in the lower proceedings. 3. The Revenue vehemently argues in this factual backdrop that various judicial precedents, including Mahender ... Ghanshyam HUF dated 16th July, 2009 relating to the taxability of interest received on compensation or enhanced compensation and also the amendments/provisions of section 56(2)(viii) introduced through Finance Act, 2009 effective from 01.04.2010 on the above issue, which the Ld. AO failed to do. The Ld. PCIT pointed

Shri Kabal Jeet Singh, Sirsa vs. DCIT/ACIT-Int.-Tax, Gurgaon

In the result, appeal of the assessee is allowed

ITA 424/CHANDI/2021[2018-19]Status: DisposedITAT Chandigarh23 Dec 2025AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2018-19 Shri Karan Jeet Singh, Vs. Dcit/Acit, 1, Hisar Road, Vpo- Intl. Taxation, Khairpur, Ward-4, Sirsa, Gurgaon Haryana Pan: Acgps7292E (Appellant) (Respondent) With Assessment Year: 2018-19 Shri Kabal Jeet Singh, Vs. Dcit/Acit, 1, Hisar Road, Vpo- Intl. Taxation, Khairpur, Ward-4, Sirsa, Gurgaon Haryana Pan: Acgps7934M (Appellant) (Respondent) With Ita Nos.390/Chandi/2021 & 590/Chandi/2022 Assessment Year: 2018-19 & 2019-20 Shri Amrish Singh, Vs. Dcit/Acit, 1, Hisar Road, Vpo- Intl. Taxation, Khairpur, Ward-4, Sirsa, Gurgaon Haryana Pan: Aszps6911K (Appellant) (Respondent) Assessee By Sh. Lalit Mohan, Adv. Sh. Ankit Kumar, Adv. Department By Sh. Mahesh Kumar, Cit(Dr) Date Of Hearing 23.12.2025 Date Of Pronouncement 23.12.2025

Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 263Section 28Section 56(2)(vii)

amounting to Rs.89,16,548/-, Rs.89,16,548/-, Rs.1,69,63,466/- and Rs.39,46,904/-, appeal-wise, respectively, taxed under section 56(2)(vii) r.w.s. 57(iv) of the Act in the lower proceedings. 3. The Revenue vehemently argues in this factual backdrop that various judicial precedents, including Mahender ... Ghanshyam HUF dated 16th July, 2009 relating to the taxability of interest received on compensation or enhanced compensation and also the amendments/provisions of section 56(2)(viii) introduced through Finance Act, 2009 effective from 01.04.2010 on the above issue, which the Ld. AO failed to do. The Ld. PCIT pointed

Shri Karan Jeet Singh, Sirsa vs. DCIT/ACIT- Int.Tax, Gurgaon

In the result, appeal of the assessee is allowed

ITA 391/CHANDI/2021[2018-19]Status: DisposedITAT Chandigarh23 Dec 2025AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2018-19 Shri Karan Jeet Singh, Vs. Dcit/Acit, 1, Hisar Road, Vpo- Intl. Taxation, Khairpur, Ward-4, Sirsa, Gurgaon Haryana Pan: Acgps7292E (Appellant) (Respondent) With Assessment Year: 2018-19 Shri Kabal Jeet Singh, Vs. Dcit/Acit, 1, Hisar Road, Vpo- Intl. Taxation, Khairpur, Ward-4, Sirsa, Gurgaon Haryana Pan: Acgps7934M (Appellant) (Respondent) With Ita Nos.390/Chandi/2021 & 590/Chandi/2022 Assessment Year: 2018-19 & 2019-20 Shri Amrish Singh, Vs. Dcit/Acit, 1, Hisar Road, Vpo- Intl. Taxation, Khairpur, Ward-4, Sirsa, Gurgaon Haryana Pan: Aszps6911K (Appellant) (Respondent) Assessee By Sh. Lalit Mohan, Adv. Sh. Ankit Kumar, Adv. Department By Sh. Mahesh Kumar, Cit(Dr) Date Of Hearing 23.12.2025 Date Of Pronouncement 23.12.2025

Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 263Section 28Section 56(2)(vii)

amounting to Rs.89,16,548/-, Rs.89,16,548/-, Rs.1,69,63,466/- and Rs.39,46,904/-, appeal-wise, respectively, taxed under section 56(2)(vii) r.w.s. 57(iv) of the Act in the lower proceedings. 3. The Revenue vehemently argues in this factual backdrop that various judicial precedents, including Mahender ... Ghanshyam HUF dated 16th July, 2009 relating to the taxability of interest received on compensation or enhanced compensation and also the amendments/provisions of section 56(2)(viii) introduced through Finance Act, 2009 effective from 01.04.2010 on the above issue, which the Ld. AO failed to do. The Ld. PCIT pointed

Sh. Amrish Singh, Sirsa vs. DCIT/ACIT, Int. Tax., Gurgaon

In the result, appeal of the assessee is allowed

ITA 390/CHANDI/2021[2018-19]Status: DisposedITAT Chandigarh23 Dec 2025AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2018-19 Shri Karan Jeet Singh, Vs. Dcit/Acit, 1, Hisar Road, Vpo- Intl. Taxation, Khairpur, Ward-4, Sirsa, Gurgaon Haryana Pan: Acgps7292E (Appellant) (Respondent) With Assessment Year: 2018-19 Shri Kabal Jeet Singh, Vs. Dcit/Acit, 1, Hisar Road, Vpo- Intl. Taxation, Khairpur, Ward-4, Sirsa, Gurgaon Haryana Pan: Acgps7934M (Appellant) (Respondent) With Ita Nos.390/Chandi/2021 & 590/Chandi/2022 Assessment Year: 2018-19 & 2019-20 Shri Amrish Singh, Vs. Dcit/Acit, 1, Hisar Road, Vpo- Intl. Taxation, Khairpur, Ward-4, Sirsa, Gurgaon Haryana Pan: Aszps6911K (Appellant) (Respondent) Assessee By Sh. Lalit Mohan, Adv. Sh. Ankit Kumar, Adv. Department By Sh. Mahesh Kumar, Cit(Dr) Date Of Hearing 23.12.2025 Date Of Pronouncement 23.12.2025

Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 263Section 28Section 56(2)(vii)

amounting to Rs.89,16,548/-, Rs.89,16,548/-, Rs.1,69,63,466/- and Rs.39,46,904/-, appeal-wise, respectively, taxed under section 56(2)(vii) r.w.s. 57(iv) of the Act in the lower proceedings. 3. The Revenue vehemently argues in this factual backdrop that various judicial precedents, including Mahender ... Ghanshyam HUF dated 16th July, 2009 relating to the taxability of interest received on compensation or enhanced compensation and also the amendments/provisions of section 56(2)(viii) introduced through Finance Act, 2009 effective from 01.04.2010 on the above issue, which the Ld. AO failed to do. The Ld. PCIT pointed

Lalchand Narayan Bhakt, Jalna vs. ITO Ward 2, Jalna

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

ITA 93/PUN/2025[2011-12]Status: DisposedITAT Pune19 Dec 2025AY 2011-12

Bench: Justice (Retd.) C V Bhadang & Shri R. K. Pandaassessment Year : 2011-12

For Appellant: Shri Hari KrishanFor Respondent: Shri A D Kulkarni
Section 133ASection 139(1)Section 142(1)Section 148Section 2(14)(iii)Section 2(47)(v)

book, he submitted that there is no such clause for forfeiture of the amount in the said agreement. Referring to the provisions of section 56(2)(ix) of the Act, he submitted that as per the said section the income shall be chargeable to tax if any sum of money ... instant case the assessee has not yet forfeited the amount and the matter is still sub-judice, therefore, the provisions of section 56(2)(ix) of the Act are also not applicable. Referring to the decision of Hon’ble Supreme Court in the case of CIT vs. Balbirsingh Maini vide

Smt Suruchi Satish Sarmalkar, Mumbai vs. ITO Ward-32(1)(1), Mumbai

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

ITA 5942/MUM/2025[2020-21]Status: DisposedITAT Mumbai19 Dec 2025AY 2020-21

Bench: Shri Sandeep Gosain& Shri Om Prakash Kant

Section 154Section 250Section 270A

have carefully considered the rival submissions. It is found that the addition in this case was made under the deeming provisions of Section 56(2)(x) of the Act. The contention of the assessee is that no penalty under Section 270A of the Act can be imposed for such deeming ... context of penalty under Section 270A of the Act for under-reporting the income. In that case also, the addition was made under Section 56(2)(x) of the Act, which was held as not falling in the category of underreporting or misreporting of income. 7.1 The assessee has also