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The ITAT dismissed the assessee's appeal, holding that the amount received by the trust without consideration for the benefit of non-relatives, and the assessee being made a partner in firms where the settlor had substantial interest, attracts the provisions of Section 56(2)(x). The term "shares" in Explanation (d) to Section 56(2)(vii) is interpreted to include "interest in partnership firm". The AO's lack of enquiry and non-application of mind to legal issues justified revisionary action u/s 263 as the order was prejudicial to revenue interests.
The ITAT dismissed the assessee's appeal, holding that the amount received by the trust without consideration for the benefit of non-relatives, and the assessee being made a partner in firms where the settlor had substantial interest, attracts the provisions of Section 56(2)(x). The term "shares" in Explanation (d) to Section 56(2)(vii) is interpreted to include "interest in partnership firm". The AO's lack of enquiry and non-application of mind to legal issues justified revisionary action u/s 263 as the order was prejudicial to revenue interests.
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