Stamp-duty value addition under Section 56(2)(x) must reflect subsequent valuation and the taxpayer's ownership share.

Addition under Section 56(2)(x) for property acquired below stamp-duty value was examined in light of a subsequently received valuation report determining a lower fair market value. The notes state that, where the assessment contemplated modification upon a lower valuation determination, the differential should be recomputed using that valuation report rather than the originally adopted stamp-duty value. The resulting difference between the valuation and declared purchase consideration was to be limited to the assessee's 50% ownership share, restricting the addition accordingly.

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Issues: Whether the addition under Section 56(2)(x) based on stamp-duty value should be computed using the subsequently received valuation report.

Analysis: The assessee disputed adoption of the stamp-duty value and sought a valuation reference. Although the assessment was completed before the valuation report became available, the report subsequently determined a lower fair market value. The assessment itself contemplated modification if the valuation authority determined a lesser value. The differential between the valuation determined and the declared consideration was required to be restricted to the assessee's 50% share.

Conclusion: The addition under Section 56(2)(x) was restricted to Rs. 8,73,650, being the assessee's share of the difference between the valuation report value and the purchase consideration, in favour of the assessee.

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