The ITAT allowed the assessee's appeal, ruling that the addition...

The ITAT allowed the assessee's appeal, ruling that the addition made under Section 56(2)(vii)(b)(ii) was invalid as this provision did not exist during the relevant assessment year. The Tribunal determined this constituted a substantive error rather than mere misquotation of law. Regarding agricultural land purchase, the ITAT held that the AO erroneously disbelieved the assessee's source of investment without contrary evidence or proper investigation, particularly considering the family's substantial landholdings. The Tribunal also found that the CIT(A) incorrectly sustained a partial addition to agricultural income despite acknowledging the assessee owned six acres at the beginning of the financial year plus additional land acquired early in the year, which should have resulted in full allowance of the claimed agricultural income.