Tenancy rights were not treated as immovable property, so section 56(2)(x) addition based on stamp duty valuation failed.

Section 56(2)(x) did not apply to acquisition of the tenancy rights because the arrangement gave only a right to occupy premises on payment of rent and did not transfer ownership or any transferable interest in immovable property. On that legal footing, stamp duty valuation could not be used to sustain the addition. The tenancy rights were therefore not treated as acquisition of property for the impugned tax charge, and the addition was deleted in favour of the assessee.

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Issues: Whether section 56(2)(x) of the Income-tax Act, 1961 applied to the acquisition of tenancy rights so as to justify the addition made on the basis of stamp duty valuation.

Analysis: The tenancy arrangement conferred only a right to occupy the premises on payment of rent and did not vest any ownership right or transferable property interest in the assessee. The record did not show transfer of property in the legal sense so as to attract section 56(2)(x). The cited authorities on leasehold or tenancy-related rights supported the view that such rights, on these facts, could not be equated with acquisition of immovable property for the purpose of the impugned addition.

Conclusion: Section 56(2)(x) was held inapplicable to the tenancy rights in question, and the addition was deleted in favour of the assessee.

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