The CIT(A) upheld the addition, holding that section 56(2)(vii)(b) applies to “any immovable property,” including agricultural land. Since rural agricultural land is expressly excluded from the definition of “capital asset” under section 2(14)(iii), it falls outside the ambit of section 56(2)(vii)(b). CIT(A)/NFAC erred in applying Section 56(2)(vii)(b) to rural agricultural land which is excluded from ‘capital asset’ u/s 2(14)(iii). CIT(A)/NFAC did not distinguish urban and rural agricultural land; the land in question is agricultural in revenue records and located outside notified municipal limits; hence exempt u/s 2(14)(iii). In the instant case, the appellant has purchased agricultural land and such agricultural land is clearly an immoveable property.