Compensatory allotment of immovable property in substitution for previously acquired land requires factual verification before treating the difference between property value and declared consideration as deemed income under section 56(2)(x). If the allotment relates to an earlier acquisition rather than a fresh purchase, section 56(2)(x) may not apply. The assessment was remitted for verification and fresh determination of taxability. Penalty for under-reporting based on the unverified deemed addition was deleted as premature, while permitting fresh penalty proceedings if under-reporting is established on reassessment.
Compensatory allotment of immovable property in substitution for previously acquired land requires factual verification before treating the difference between property value and declared consideration as deemed income under section 56(2)(x). If the allotment relates to an earlier acquisition rather than a fresh purchase, section 56(2)(x) may not apply. The assessment was remitted for verification and fresh determination of taxability. Penalty for under-reporting based on the unverified deemed addition was deleted as premature, while permitting fresh penalty proceedings if under-reporting is established on reassessment.
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