Income Tax Act Section 56(2)(vii)(b)(i) upheld for land value discrepancy; intent to sell unproven by assessee.

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....Addition u/s 56(2)(vii)(b)(i) - difference between the actual purchase consideration of plots of land and market value as per stamp valuation authorities - Assessee has not demonstrated before us that whether he fulfils the criteria for treating the purchase of three plots as a stock in trade of his business. Merely presumption by the assessee that those three plots were intended for further sale and therefore those were stock in trade, is not sufficient and it has to be proved by way of evidences, which the assessee has failed - AT....