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    <title>2019 (9) TMI 338 - ITAT BANGALORE</title>
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    <description>Tax treatment of receipt and allotment of share application money was considered: revenue failed to establish unexplained cash credit and therefore provisions akin to challenge under unexplained share receipts could not be sustained, resulting in deletion of the impugned addition. Receipt of share consideration from non-residents does not attract the special valuation provision applicable to resident subscriptions, and where shares were issued at face value with no premium the valuation provision is inapplicable, resulting in no charge on that ground. Conversion of application money into allotted equity under board resolution was accepted, and the addition was directed to be deleted in favour of the assessee.</description>
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      <link>https://www.taxtmi.com/caselaws?id=385570</link>
      <description>Tax treatment of receipt and allotment of share application money was considered: revenue failed to establish unexplained cash credit and therefore provisions akin to challenge under unexplained share receipts could not be sustained, resulting in deletion of the impugned addition. Receipt of share consideration from non-residents does not attract the special valuation provision applicable to resident subscriptions, and where shares were issued at face value with no premium the valuation provision is inapplicable, resulting in no charge on that ground. Conversion of application money into allotted equity under board resolution was accepted, and the addition was directed to be deleted in favour of the assessee.</description>
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