Valuation date under section 56(2)(x) must match the proviso date where earnest money was paid earlier.

Where the proviso to section 56(2)(x) applies, the relevant property value must be determined with reference to the date fixed by that proviso, not a later valuation date used in assessment. Here, earnest money had been paid in December 2017, but the assessment relied on a DVO valuation as of March 2020. Because that mismatch affected the basis of the addition, the existing valuation could not be treated as conclusive. The matter was therefore sent back for fresh valuation with reference to December 2017, giving the assessee partial relief.

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Issues: Whether the addition under section 56(2)(x) of the Income-tax Act, 1961 could be sustained on a valuation determined as of March 2020, or whether the property was required to be valued as of December 2017 because earnest money had been paid in that year.

Analysis: The assessment had proceeded on the basis of the DVO valuation made with reference to 20 March 2020. The record showed, however, that the assessee had paid earnest money in December 2017, and the applicability of the proviso to section 56(2)(x) required the relevant value to be considered with reference to that earlier date. In view of this mismatch between the valuation date adopted in the assessment and the date mandated by the proviso, the existing valuation could not be treated as conclusive for the purpose of the addition. The matter therefore required fresh valuation in consultation with the DVO.

Conclusion: The issue was restored to the Assessing Officer for limited reconsideration of the property's value as of December 2017, and the assessee obtained partial relief.

Ratio Decidendi: Where the proviso to section 56(2)(x) applies, the relevant valuation must correspond to the date fixed by that proviso, and a valuation based on a later date cannot be sustained without fresh determination.

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