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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)

Sh. Randhir Singh, Sirsa vs. PCIT Rohtak, Rohtak

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 494/CHANDI/2024[2013-14]Status: DisposedITAT Chandigarh24 Feb 2026AY 2013-14

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

Section 143(3)Section 263

such. 8.2 That the learned Principal Commissioner of Income Tax has further erred both in law and on fact in invoking section 56(2)(viii) read with sections 57(iv) and 145A(b) of the Act to make the impugned addition. 8.3 That the Principal Commissioner of Income ... such. 8.2 That the learned Principal Commissioner of Income Tax has further erred both in law and on fact in invoking section 56(2)(viii) read with sections 57(iv) and 145A(b) of the Act to make the impugned addition. 8.3 That the Principal Commissioner of Income

Surjeet Singh, Sirsa vs. PCIT, Rohtak

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 488/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh24 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

Section 143(3)Section 263

such. 8.2 That the learned Principal Commissioner of Income Tax has further erred both in law and on fact in invoking section 56(2)(viii) read with sections 57(iv) and 145A(b) of the Act to make the impugned addition. 8.3 That the Principal Commissioner of Income ... such. 8.2 That the learned Principal Commissioner of Income Tax has further erred both in law and on fact in invoking section 56(2)(viii) read with sections 57(iv) and 145A(b) of the Act to make the impugned addition. 8.3 That the Principal Commissioner of Income

Sh. Paramjeet Singh, Sirsa vs. PCIT, Rohtak

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 290/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh24 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

Section 143(3)Section 263

such. 8.2 That the learned Principal Commissioner of Income Tax has further erred both in law and on fact in invoking section 56(2)(viii) read with sections 57(iv) and 145A(b) of the Act to make the impugned addition. 8.3 That the Principal Commissioner of Income ... such. 8.2 That the learned Principal Commissioner of Income Tax has further erred both in law and on fact in invoking section 56(2)(viii) read with sections 57(iv) and 145A(b) of the Act to make the impugned addition. 8.3 That the Principal Commissioner of Income

Dhuni Chand HUF, Sirsa vs. PCIT, Rohtak

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 289/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh24 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

Section 143(3)Section 263

such. 8.2 That the learned Principal Commissioner of Income Tax has further erred both in law and on fact in invoking section 56(2)(viii) read with sections 57(iv) and 145A(b) of the Act to make the impugned addition. 8.3 That the Principal Commissioner of Income ... such. 8.2 That the learned Principal Commissioner of Income Tax has further erred both in law and on fact in invoking section 56(2)(viii) read with sections 57(iv) and 145A(b) of the Act to make the impugned addition. 8.3 That the Principal Commissioner of Income

Sh. Kashmir Singh Sandha, Sirsa vs. PCIT, Rohtak

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 288/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh24 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

Section 143(3)Section 263

such. 8.2 That the learned Principal Commissioner of Income Tax has further erred both in law and on fact in invoking section 56(2)(viii) read with sections 57(iv) and 145A(b) of the Act to make the impugned addition. 8.3 That the Principal Commissioner of Income ... such. 8.2 That the learned Principal Commissioner of Income Tax has further erred both in law and on fact in invoking section 56(2)(viii) read with sections 57(iv) and 145A(b) of the Act to make the impugned addition. 8.3 That the Principal Commissioner of Income

M/S Ganesh Dass HUF, Sirsa vs. PCIT, Rohtak

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 287/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh24 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

Section 143(3)Section 263

such. 8.2 That the learned Principal Commissioner of Income Tax has further erred both in law and on fact in invoking section 56(2)(viii) read with sections 57(iv) and 145A(b) of the Act to make the impugned addition. 8.3 That the Principal Commissioner of Income ... such. 8.2 That the learned Principal Commissioner of Income Tax has further erred both in law and on fact in invoking section 56(2)(viii) read with sections 57(iv) and 145A(b) of the Act to make the impugned addition. 8.3 That the Principal Commissioner of Income

Sh. Arvail Singh, Sirsa vs. PCIT, Rohtak

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 286/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh24 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

Section 143(3)Section 263

such. 8.2 That the learned Principal Commissioner of Income Tax has further erred both in law and on fact in invoking section 56(2)(viii) read with sections 57(iv) and 145A(b) of the Act to make the impugned addition. 8.3 That the Principal Commissioner of Income ... such. 8.2 That the learned Principal Commissioner of Income Tax has further erred both in law and on fact in invoking section 56(2)(viii) read with sections 57(iv) and 145A(b) of the Act to make the impugned addition. 8.3 That the Principal Commissioner of Income

Oragadam City Developers Pvt. Ltd., Chennai vs. ITO, Corporate Ward-5(1), Chennai

In the result, Addition u/s

ITA 2173/CHNY/2025[2014-15]Status: DisposedITAT Chennai23 Feb 2026AY 2014-15

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunatha

For Appellant: MR. R. Sivaraman, AdvFor Respondent: Mr. Guru Prasad, Addl. CIT
Section 143(2)Section 147Section 148Section 40Section 56(2)(viib)

Oragadam City Developers Pvt Ltd(Vs.) ITO CW5(1) :: 3 :: at a premium took place in FY 2013-14. The assessee submitted that Section 56(2)(viib) was inapplicable as the consideration had been received in earlier years. The assessee further relied upon a valuation report adopting the Discounted Cash ... unreliable. The fair market value (FMV) of the shares was determined at Rs.10/- per share, being the face value. The AO held that Section 56(2)(viib) applies to any consideration received for issue of shares to a resident in excess of the FMV, irrespective of whether the underlying funds

Bharatkumar Haridas Mehta, Mumbai vs. DCIT, Mumbai

In the result, the appeal of the assessee is allowed

ITA 8409/MUM/2025[2018-19]Status: DisposedITAT Mumbai23 Feb 2026AY 2018-19

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2018-19

For Respondent: Mr. K. Gopal, Adv. And
Section 56(2)(x)

confirming the addition of Rs. 5,83,371/- The Ld. CIT(A) erred in confirming the addition of Rs. 5,83,371/ under section 56(2)(x) without properly appreciating the facts a under section 56(2)(x) without properly appreciating the facts a under section 56(2)(x) without ... date of booking/allotment, contrary of registration instead of the date of booking/allotment, contrary to the mandatory First and Second Provisos to section 56(2)(x), to the mandatory First and Second Provisos to section 56(2)(x), to the mandatory First and Second Provisos to section 56(2)(x), despite

Bihari Parmanand Kandhari, Mumbai vs. Aci, Circle -23(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 7925/MUM/2025[2018-19]Status: DisposedITAT Mumbai23 Feb 2026AY 2018-19

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2018-19

For Respondent: Mr. Akshay Jain
Section 56(2)

addition of The central issue in this appeal pertains to an addition of ₹3,92,87,988/- made under made under Section 56(2)(x) of the Income of the Income-tax Act, 1961 ("the Act"). During the assessment proceedings under Act, 1961 ("the Act"). During the assessment proceedings under ... assessee through banking channels at that time. Consequently, the assessee sought the benefit of the sought the benefit of the proviso to Section 56(2), which mandates , which mandates that where the date of agreement and the date of registration are that where the date of agreement and the date

Bhupendra Flour Mills Pvt Ltd, Bathinda vs. ITO, Ward 1(1), Bathinda

The appeal stands partly allowed in terms of out above order

ITA 54/ASR/2025[2017-18]Status: DisposedITAT Amritsar20 Feb 2026AY 2017-18

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Shri Udayandasgupta, Jm आयकरअपीलसं. / Ita No.54/Asr/2025 (िनधा"रणवष" / Assessment Year: 2017-18) M/S Bhupendra Flour Mills Pvt Ltd. Ito Ward - 1(1) बनाम/ Railway Road Central Revenue Building Bhatinda, Punjab – 151001 Civil Lines, Bhatinda Vs. Punjab - 151001 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aaccb-6192-P (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Sudhir Sehgal (Advocate) - Ld. Ar " थ"कीओरसे/Respondent By : Sh. Farhat Khan (Cit) – Ld. Dr (Virtual) सुनवाईकीतारीख/Date Of Hearing : 05-02-2026 घोषणाकीतारीख /Date Of Pronouncement 20.02.2026 : आदेश / O R D E R

For Appellant: Sh. Sudhir Sehgal (Advocate) - Ld. ARFor Respondent: Sh. Farhat Khan (CIT) – Ld. DR (Virtual)
Section 10(37)Section 14Section 143(3)Section 145B(1)Section 194LSection 2Section 2(24)Section 36Section 4Section 45(5)

from a conjoint reading of the relevant statutory provisions of the income tax after its amendment w.e.f 1/4/2010 reproduced hereinabove : (i) By inserting Section 56(2)(viii) and Section 145B(1) with effect from 1st April 2010, the Legislature introduced a specific charging mechanism mandating that interest received on compensation ... income and a clear basis of charge for interest on such compensation. (iii) It is pertinent to note that the opening words of Section 56(2)—“In particular, and without prejudice to the generality of the provisions of sub section (1), the following incomes shall be chargeable to income

Ashok Lalchand Jain, Mumbai vs. ITO 12(1)(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 8315/MUM/2025[2020-21]Status: DisposedITAT Mumbai20 Feb 2026AY 2020-21

Bench: Shri Narender Kumar Choudhry & Shri Jagadishassessment Year: 2020-21

Section 143(3)Section 35Section 56(2)(x)

circumstances of the case and in law, the Ld. CIT has erred in confirming the addition of Rs.62,01,745/- under section 56(2)(x) made by the Ld. AO being the difference between the stamp duty value of Rs.2,37,75,745/- and the agreement value of Rs.1 ... observed that there was a difference of ₹62,01,745/- between the stamp duty value and the purchase consideration. Invoking the provisions of section 56(2)(x) of the Act, the Assessing Officer treated the differential amount as income from other sources and made the 2 Ashok Lalchand Jain addition

Sudhanshu Infrastructures Private Limited, Bhandup(W) vs. Circle 15(3)(2), Aayakar Bhawan, Mumbai

ITA 7654/MUM/2025[2018-19]Status: DisposedITAT Mumbai20 Feb 2026AY 2018-19

Bench: Smt Beena Pillai, Jm & Shri Arun Khodpia, Am

For Appellant: Shri Surji Chheda (Virtually present), ARFor Respondent: Assessee by
Section 143(3)Section 48Section 50CSection 50C(1)Section 56(2)(X)Section 56(2)(x)

Being the Market Value of properties are higher than the sale consideration shown by the assessee, the ld. AO invoked the provisions of section 56(2)(x) of the Act and have made the addition of the excess of Market Value over the actual sale consideration. The details of properties ... transactions has been arrived at Rs. 5,13,339/-, which was added to the income of assessee by the ld. AO under section 56(2)(x)(B) r.w.s. 50C(1) of the act. While making the aforesaid addition, the ld. AO referred to the provisions of section 56(2

Ramani Mathuraprasad Mishra, Mumbai vs. ITO Ward 22(3)(6), Mumbai

ITA 7543/MUM/2025[2017-18]Status: DisposedITAT Mumbai20 Feb 2026AY 2017-18

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI MAKARAND VASANT MAHADEOKAR (Accountant Member)

For Appellant: Shri Naimish JoshiFor Respondent: Date
Section 143(1)(a)Section 144Section 144BSection 147Section 56(2)(vii)

income for the Assessment Year 20172-108 at INR.1,23,91,862/- after making the following additions/disallowances: (a) INR.39,20,555/- disallowed under Section 56(2)(vii)(b) (b) INR.11,00,600/- disallowed on account of commission and brokerage expenses 2 Assessment Year 2017-2018 (c) INR.53,90,000/- disallowed ... amount of INR.39,20,555/- was added on account of the difference between the market value and stamp duty value under section 56(2)(vii)(b) of the Act (b) An amount of INR.1,40,00,000/- was added on account of unexplained Investment for the purchase of the said

Nokha Trading LLP, Bangalore vs. DCIT, Circle-1(1)(1), Bangalore

In the result, the appeal of the assessee is partly allowed

ITA 2397/BANG/2025[2018-19]Status: DisposedITAT Bangalore19 Feb 2026AY 2018-19

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2018-19

For Appellant: Shri Ankit Marlecha, CAFor Respondent: Shri Subramanian S., Jt.CIT(DR)(ITAT), Bengaluru
Section 1Section 10Section 10(35)Section 143(2)Section 143(3)Section 144BSection 56(2)(i)

business income, without appreciating that (a) dividend income is taxable as income from business or profession, by virtue of specific mention under section 56(2)(i) and not under business or profession; Page 3 of 10 (b) the learned AO in the assessment order had positively accepted the returned income

Indutch Composites Technology Private Limited, Vadodara vs. Deputy Commissioner, Circle 1(1)(1), Vadodara

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

ITA 2004/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad18 Feb 2026AY 2014-15

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), SHRI SIDDHARTHA NAUTIYAL (Judicial Member)

For Appellant: Shri Nishit Shah, ARFor Respondent: Shri C Dharani Nath, Sr.DR
Section 250Section 56(2)

justice. 3. On the facts and in law, the learned CIT(A) further erred in confirming the addition of Rs.60,95,145/- under section 56(2) (viib) by arbitrarily rejecting the Discounted Cash Flow (DCF) method of share valuation adopted by the appellant as per Rule 11UA, and in accepting ... from a qualified valuer if the original report was found technically deficient. 5. The warned CIT(A) erred in confirming the addition under section 56(2) (vib) in respect of shares issued to non residents, despite clear documentary evidence including board resolutions indicating that a substantial portion of the shares

Cherie Tandon Saldahna, Mumbai vs. DCIT, Circle 23(1), Mumbai

ITA 6576/MUM/2025[2018-19]Status: DisposedITAT Mumbai18 Feb 2026AY 2018-19
Section 142(1)Section 143(2)Section 143(3)Section 144BSection 56(2)(x)

case and in law, the Ld. CIT(A) erred in confirming the action of the Ld. AO in applying the provisions of section 56(2)(x) and making an addition of Rs. 1,14,87,300, while ignoring the proviso to section 56(2)(x) which is applicable ... allotment i.e. 03.05.2011. Such addition is bad in law." 3. The solitary grievance of the assessee is against the addition made under section 56(2)(x) of the Act in respect of two residential flats purchased by the assessee. 4. The brief facts of the case pertaining to this issue

Vallabhbhai Dudabhai Chhatrala, Surat vs. ITO, Ward-3(3) (1), Surat

In the result, the grounds of appeal raised by the assessee is allowed

ITA 815/SRT/2025[2011-12]Status: DisposedITAT Surat17 Feb 2026AY 2011-12

Bench: Dr. B.R.R. Kumar, Vice-Ms Suchitra Kamblevallabhbhai Dudabhai Chhatrala, The Income Tax Officer, Vs. 6, Prabhu Darshan Soc. Nr. Ward-3(3)(5), Dhameliya Nagar, Current Jurisdiction, Varacha Road, Ward-3(3)(1), Rajhans Point, Surat-395006. Surat-395006. [Pan : Aeepc8550 M] (Appellant) .. (Respondent) Appellant By : Shri Mehul Shah, Ar Respondent By: Shri Ajay Uke, Sr. Dr Date Of Hearing 22.01.2026 Date Of Pronouncement 17.02.2026 O R D E R Per Dr. B.R.R. Kumar, Vice-:-

For Appellant: Shri Mehul Shah, ARFor Respondent: Shri Ajay Uke, Sr. DR
Section 147Section 148Section 250Section 69

converted from Section 69 to 56(2)(x)(b) of the Act or any direction was given. We find that the provisions of section 56(2)(x)(b) was inserted in the statue book from AY 2014-15, thus, no such provisions are applicable on the transaction of assessee. Even ... otherwise, there is no finding of ld CIT(A) to make addition under section 56(2) (x)(b). So far as finding of lower authorities that they are in possession of a satakat 3. executed by the original owners with Shankar Chaganlal Shah and Govind K. Bhadiyadra for a consideration

Ratibhai Girdharbhai Kakani, Surat vs. Asst. Commissioner of Income Tax, Circle 1(3), Surat

In the result, the appeal of the assessee is allowed

ITA 1025/SRT/2025[2015-16]Status: DisposedITAT Surat17 Feb 2026AY 2015-16

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

Section 250Section 55ASection 56(2)(vii)

proceedings, the Assessing Officer observed that the stamp duty valuation of the property was Rs.4,65,57,750/- and, invoking the provisions of section 56(2)(vii)(b) of the Act, made an addition of Rs.1,16,21,427/- being the difference between the stamp duty value and the actual ... Assessing Officer and Ld. CIT(A). 5.1 The issue for consideration is whether the addition of Rs.1,16,21,427/- under section 56(2)(vii)(b) of the Act is sustainable. Straight to the issue: 5.2 The Assessing Officer made an addition of Rs.1,16,21,427/- under section 56

Karadi Path Education Company Private Limited, Chennai vs. Commissioner, Chennai

ITA 1848/CHNY/2025[2018-2019]Status: DisposedITAT Chennai17 Feb 2026AY 2018-2019

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:1848/Chny/2025 निर्धारण वर्ष / Assessment Year: 2018-19 Karadi Path Education Company Private Limited, 3A No.11, Dev Regency, I Main Road, Gandhi Nagar, Adyar, Chennai - 600 020. [Pan: Aaeck-2995-D] (अपीलार्थी/Appellant) Dcit, Vs. Corporate Circle -4(1), Chennai. (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/Appellant By : Shri. Pradhan Priya Dass, C.A. (By Virtual) प्रत्यर्थी की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/Date Of Hearing : 27.11.2025 घोषणा की तारीख/Date Of Pronouncement : 17.02.2026 आदेश /O R Der Per S. R. Raghunatha, Am: This Appeal By The Assessee Is Filed Against The Order Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, (In Short “Ld.Cit(A)”) For The Assessment Year 2018-19, Dated 29.04.2025 In Respect Of The Order Of The National E-Assessment Centre, Delhi (In Short 'Ao') Passed U/S.143(3) Of The Income Tax Act, 1961 ( In Short ‘The Act') Dated 28.04.2021. :-2-:

For Appellant: Shri. Pradhan Priya Dass, C.A. (by Virtual)For Respondent: Ms. Gouthami Manivasagam, JCIT
Section 143(3)Section 56(2)(vii)Section 56(2)(viib)

ITAT decision of Sudhir Menon HUF vs. Asst. CIT(A) (ITA No. 192/Mum/2013) which :-3-: ITA. No:1848/Chny/2025 was in the context of Section 56(2)(vii)(b) / 56(2)(vii)(c) and not in the context of Section 56(2)(viib) of the Income-tax Act. For these ... report dated 19.09.2017 prepared by an independent Chartered Accountant adopting the DCF method. The Assessing Officer rejected the valuation report and held that section 56(2)(viib) of the Act applies even to conversion of loan into equity. Further, the Assessing Officer held that the valuation report was invalid since