https://www.taxtmi.com/caselaws?id=438635 ITAT DELHI - AT allowed the appeal, quashed the Pr. CIT's revision under s.263 and restored the AO's assessment. The Tribunal held that s.56(2)(viib) cannot be invoked to deem income on share premium between interrelated holding and subsidiary where no outsider benefits, so the revisional scope was lacking; preliminary inquiry by the revisional authority was absent and no prejudice could arise from further inquiry. Findings under s.68 and the AO's post-revision satisfaction supported cancellation of the revisional order in favour of the assessee. en-us Wed, 31 May 2023 00:00:00 +0530 Thu, 28 Aug 2025 12:01:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=438635 ITAT DELHI - AT allowed the appeal, quashed the Pr. CIT's revision under s.263 and restored the AO's assessment. The Tribunal held that s.56(2)(viib) cannot be invoked to deem income on share premium between interrelated holding and subsidiary where no outsider benefits, so the revisional scope was lacking; preliminary inquiry by the revisional authority was absent and no prejudice could arise from further inquiry. Findings under s.68 and the AO's post-revision satisfaction supported cancellation of the revisional order in favour of the assessee. Case-Laws Income Tax Wed, 31 May 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=438635