High Market Valuation of Land Deemed Irrelevant in Share Value Discrepancy Case u/s 56(2)(vii)(b) of Income Tax Act.

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....Addition u/s 56(2)(vii)(b) - difference in the market value and issued value of shares - assessee had established through various evidences submitted during appeal proceedings that even if Guideline value of land is considered than also the valuation of land is very high. Even the Ld. AO in its remand report, admitted the same fact of high market valuation of land but further mentioned that the same is not a relevant evidence which is against the provisions of section 56(2)(viib). - AT....