Stamp duty valuation addition requires factual verification before section 56(2)(x)(b) can be applied to disputed land classification.

Addition under section 56(2)(x)(b) based on stamp duty valuation could not be sustained without verifying the assessee's claim that the purchased property was agricultural land and that the stamp valuation was wrongly applied as if it were residential. Because these factual contentions had not been examined by the lower appellate authority and no verification had been made from the stamp valuation authorities, further inquiry was required. The matter was therefore remanded to the CIT(A) for fresh adjudication and necessary verification in accordance with law, leaving the substantive tax issue open.

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Issues: Whether the addition made under section 56(2)(x)(b) on the basis of stamp duty valuation of the land purchase could be sustained without verification of the assessee's claim that the property was agricultural land and that the higher stamp valuation was wrongly applied.

Analysis: The assessee challenged the addition on the ground that the property purchased was agricultural land and that the stamp authority had wrongly treated it as residential, resulting in an inflated valuation. It was also asserted that the valuation mechanism invoked by the Revenue was not applicable to the facts stated. As these contentions were not examined by the lower appellate authority and no verification was undertaken from the stamp valuation authorities, further factual inquiry was necessary.

Conclusion: The matter was restored to the file of the CIT(A) for fresh examination and necessary verification in accordance with law, and the assessee's grounds were allowed for statistical purposes.

Final Conclusion: The addition was not finally affirmed and the controversy was sent back for reconsideration, leaving the substantive tax issue open at the appellate stage.

Ratio Decidendi: Where the applicability of a stamp-value based addition depends on disputed factual matters, the issue cannot be conclusively decided without verification and must be remanded for fresh adjudication.

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