Agricultural land falls within section 56(2)(x) as immovable property; DVO valuation-based addition sustained.

Section 56(2)(x) applies to receipt of immovable property for inadequate consideration, and agricultural character does not take the land outside its scope. The buyer's tax liability depends on the nature of the property received, not on whether the land would be agricultural for transferor-side capital gains purposes. The DVO-based valuation, already relied on by the assessee in the co-owner's case and found to have considered objections, was accepted as the basis for the addition. The request for a fresh valuation was rejected, and the addition based on the difference between the DVO value and the disclosed consideration was sustained.

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Issues: (i) Whether section 56(2)(x) of the Income-tax Act, 1961 applied to the purchase of agricultural land as an immovable property. (ii) Whether the addition based on the DVO's valuation and the difference between such valuation and the consideration paid was liable to be deleted.

Issue (i): Whether section 56(2)(x) of the Income-tax Act, 1961 applied to the purchase of agricultural land as an immovable property.

Analysis: The provision covers receipt of any immovable property for inadequate consideration and does not restrict its operation to non-agricultural land or to a capital asset. The character of the land as agricultural may be relevant for the transferor's capital gains computation, but that distinction does not control the buyer's tax liability under section 56(2)(x). The statutory text specifically refers to immovable property, and agricultural land falls within that expression.

Conclusion: Section 56(2)(x) was correctly invoked, and the objection that the land was agricultural did not exclude the transaction from its scope.

Issue (ii): Whether the addition based on the DVO's valuation and the difference between such valuation and the consideration paid was liable to be deleted.

Analysis: The assessee had itself relied on the DVO's valuation in the co-owner's case as the proper basis for computation. The record showed that the DVO had considered the objections raised and determined the value accordingly. In these circumstances, there was no justification to disregard that valuation or to direct a fresh determination merely because the assessee later disputed it. The addition was computed on the basis of the difference between the DVO-determined value and the consideration disclosed.

Conclusion: The addition of Rs. 14,16,098 was rightly sustained and no fresh valuation exercise was warranted.

Final Conclusion: The assessment addition was upheld and the assessee's challenge failed in full.

Ratio Decidendi: For section 56(2)(x), the relevant inquiry is whether the property received is an immovable property for inadequate consideration; agricultural character does not exclude its application, and a valuation adopted at the assessee's instance cannot be reopened absent a legally sustainable basis.

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