Gifted agricultural land is not taxable as money under section 56, and a registered transfer was found genuine.

Receipt of agricultural land under a registered gift/release deed was not taxable under section 56(2)(v) because the phrase "any sum of money" was confined to money and did not extend to immovable property. The alternative invocation of section 56(1) also failed because gifted agricultural land is not income and cannot be taxed as income from other sources merely because it does not fit another head. The transfer was held genuine: the donor's ownership appeared in balance sheets, the deed was registered, stamp duty was paid, and the requirements of sections 122 and 123 of the Transfer of Property Act, 1882 were satisfied, with no evidence of consideration or sham arrangement.

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Issues: Whether receipt of agricultural land by way of registered gift/release deed could be taxed under section 56(2)(v) or section 56(1) of the Income-tax Act, 1961, and whether the gift was liable to be disbelieved as non-genuine.

Analysis: The expression "any sum of money" in section 56(2)(v) was held to cover money alone and not immovable property. The legislative purpose behind the provision was to tax certain monetary receipts and curb money laundering, not to bring within its scope a transfer of agricultural land. Since an immovable property cannot be equated with a sum of money, the receipt did not fall within section 56(2)(v). The alternative reliance on section 56(1) also failed because an agricultural land received as a gift is not income and cannot be brought to tax as income from other sources merely because the receipt is not otherwise taxable under the specified heads. The transfer was also found to be genuine: the donor's ownership was reflected in her balance sheets, the deed was registered, stamp duty was paid, and the requirements of sections 122 and 123 of the Transfer of Property Act, 1882 were satisfied. No material showed payment of consideration or any sham arrangement.

Conclusion: The receipt of agricultural land was not taxable under section 56(2)(v) or section 56(1), and the gift could not be treated as non-genuine.

Final Conclusion: The deletion of the addition was sustained and the revenue's challenge failed.

Ratio Decidendi: The phrase "sum of money" in section 56(2)(v) of the Income-tax Act, 1961 is confined to monetary receipts and does not extend to immovable property gifted without consideration; such a receipt cannot be taxed as income under section 56(1) either.

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