Section 56(2)(viib) of the income tax Act, 1961 — Income from other sources — Addition made under section 56(2)(viib) by ignoring the fair market value of assets as per second limb of explanation to section 56(2)(viib) could not be sustained as second limb of explanation (a) to section 56(2)(viib) itself provides for determination of FMV based on value of underlying assets and as a corollary, the value once substantiated would be replaced with the book value for the purposes of FMV regardless of the book entries in this regard — Unnati Inorganics P. Ltd. vs. Income tax Officer [2019] 202 TTJ (Ahmedabad) 347