07 Jul Assessee which have exercised the option considering according to Expln
AO during the reassessment process, refused the valuation declaration, on to the floor however report was not recorded throughout the amazing testing proceedings, and you can taxed the fresh new superior accumulated because of the invoking sec 56(2)(viib).
Yet not, new evaluating manager did not take on the above mentioned entry of the assessee and you may added forty% from area fee received up against deals away from house, towards overall earnings of your assessee since the unexplained income you/s 69 of your Act towards the protective foundation
(a)(ii) to sec. 56(2)(viib), and achieving substantiated this new reasonable market value out-of offers based on valuation declaration, since the towards the time away from problem of offers, there isn't any scope in order to invoke specifications out of sec 56(2)(viib) in order to income tax share premium accumulated for the factors from shares.