Assessee is a private discretionary trust and was established under the provisions of Indian Trust Act, 1882 vide settlement deed dated January 23, 2018 executed between Mr. Anand Nadathur, being the Settlor and Vervain Management Private Limited, being the Trustee. The settlor settled investments amounting to INR 669,.27 crores , to the trust out of natural love and affection . The assessment was completed u/s 143(3) of the Act . Commissioner revised the order on the ground that the AO has failed to conduct any enquiries due to which the order of the AO is erroneous and prejudicial to the interest of revenue.  On appeal the issue of jurisdiction u/s 263 was not argued . Tribunal held that revision is justified on law and facts . Affirming the Revision order the Tribunal  held that  the benefit of the amount received was not restricted to the family members and hence the view of the AO is not plausible view therefore the PCIT is correct in law in holding the order as prejudicial to the interest of revenue.  Tribunal also held that the term shares and securities has been used it is abundantly clear that “and” should be read as “or”. Further literal interpretation in the present case is also giving an absurd meaning therefore the expression “and” used here should be read as “or” .Therefore  interest in partnership firm falls in the category of “shares” as used in explanation (d) of section 56(2)(vii). What is “interest in partnership firm” has been decided by so many judicial pronouncements wherein this expression has been interpreted of expression. Accordingly  the term shares as used in explanation-2 of section 56(2)(vii) is not restricted to the shares of companies only, rather it is wide enough to mean a part or portion of something. For instance, “sharing” refers to dividing or giving out portions of something among several people. Merely because some expression is missing Tribunal  cannot restrict the meaning of a word. Tribunal held that it is settled position of law that that words should not be overly restricted; their meaning can be shaped by the context in which they are used. Legal texts, contracts, or laws often define words, but if a specific definition is not provided, courts or authorities may interpret the word according to its common usage or the broader context. Therefore the Tribunal has taken   the common meaning of word “share”. As the  interest in partnership firm is nothing rather shares of partnership firm .Accordingly the Revision is affirmed on law and merit .(ITA No.1051 /Bang/2024 dt.30 -12 -2024 )( AY.2018 -19 )