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of <h1>CBDT Clarifies Section 56(2)(viia) Applicability: Fresh Share Issuance Not Exempt; Overrules Circular No. 10/2018 Misinterpretation.</h1> The Central Board of Direct Taxes issued Circular No. 3/2019 clarifying the applicability of section 56(2)(viia) of the Income-tax Act, 1961, concerning the issuance of shares by companies not substantially interested by the public. The Board reviewed the interpretation of 'receives' in this context, emphasizing that section 56(2)(viia) and similar provisions are anti-abuse measures. It was clarified that the position in Circular No. 10/2018, which excluded fresh share issuance from section 56(2)(viia), was incorrect and should not be considered in any proceedings, as it contradicts legislative intent.
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