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Issues: Whether the receipt of India Millennium Deposit certificates constituted receipt of "any sum of money" so as to attract section 56(2)(v) of the Income-tax Act, 1961.
Analysis: Section 56(2)(v) applied only where an individual or Hindu undivided family received a sum of money without consideration. The deposit certificates were subject to transfer restrictions and were not freely usable as money or a medium of exchange. They were only instruments capable of being converted into money and therefore fell within the category of property received in kind. The later insertion of section 56(2)(vii), which brought gifts in kind within the charging provision, operated prospectively and could not govern the assessment year in question.
Conclusion: The receipt of the certificates was not taxable under section 56(2)(v) and the addition was rightly deleted.
Final Conclusion: The departmental appeal failed and the relief granted by the first appellate authority was upheld.
Ratio Decidendi: For the relevant period, section 56(2)(v) covered only receipt of money and not a gift received in kind, even if the gifted asset was convertible into money.