Assessee-company, engaged in business of real estate development, acquired immovable land during the year in the normal course of business and disclosed the same as stock-in-trade. Similar land transactions for the immediately preceding assessment year had been examined by the Assessing Officer in scrutiny proceedings as well as in revision under section 263, and return was accepted without any addition. On the basis of the same material, the Assessing Officer issued a notice under section 148A alleging understatement of consideration and applicability of section 56(2)(x). On writ, the Court held that section 56(2)(x) applies only where a capital asset is received with or without consideration. Since land in question was held as stock-in-trade and transactions stood fully disclosed and examined, provisions of section 56(2)(x) were not applicable. Court held that in the absence of any new tangible material and where provisions of section 56(2)(x) were not applicable on merits, initiation of reassessment proceedings was unsustainable. Reassessment notice and consequential orders were quashed. (AY. 2021-22)