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Section 56(2)(x) was treated as inapplicable where land was acquired solely through purchase of leasehold rights rather than ownership rights in land. The interpretation followed co-ordinate Tribunal decisions that compared the provision with Section 50C and adopted the view favourable to the assessee amid conflicting High Court views. Characterising the transaction as a sale of land did not change its legal character as a transfer of leasehold rights. The related addition was deleted.
Section 56(2)(x) was treated as inapplicable where land was acquired solely through purchase of leasehold rights rather than ownership rights in land. The interpretation followed co-ordinate Tribunal decisions that compared the provision with Section 50C and adopted the view favourable to the assessee amid conflicting High Court views. Characterising the transaction as a sale of land did not change its legal character as a transfer of leasehold rights. The related addition was deleted.
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