https://www.taxtmi.com/caselaws?id=446851 The ITAT Surat reversed the CIT's revision order under Section 263 regarding the applicability of Section 56(2)(x) to co-owners who were not original parties to a property agreement. The assessee held a 7% share among ten co-owners. The CIT had denied benefits of the first and second proviso to Section 56(2)(x)(b) since the assessee wasn't party to the original agreement and made no direct payment. However, the ITAT found that part consideration was paid by family members and close relatives of the assessee. Following the Mumbai ITAT precedent in Sulochana Saijan Modi, the tribunal held that the AO's assessment accepting returned income was not erroneous, thus the twin conditions for invoking Section 263 were not satisfied. en-us Wed, 27 Sep 2023 00:00:00 +0530 Tue, 12 Dec 2023 12:59:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=446851 The ITAT Surat reversed the CIT's revision order under Section 263 regarding the applicability of Section 56(2)(x) to co-owners who were not original parties to a property agreement. The assessee held a 7% share among ten co-owners. The CIT had denied benefits of the first and second proviso to Section 56(2)(x)(b) since the assessee wasn't party to the original agreement and made no direct payment. However, the ITAT found that part consideration was paid by family members and close relatives of the assessee. Following the Mumbai ITAT precedent in Sulochana Saijan Modi, the tribunal held that the AO's assessment accepting returned income was not erroneous, thus the twin conditions for invoking Section 263 were not satisfied. Case-Laws Income Tax Wed, 27 Sep 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=446851