https://www.taxtmi.com/caselaws?id=751169 ITAT Mumbai dismissed revenue's appeal regarding additions under sections 68 and 56(2)(viib) for share premium receipts. The AO had questioned premium of Rs. 40 per share (face value Rs. 10) for a loss-making company without valuation basis. ITAT held that once identity, creditworthiness, and genuineness of transactions with Future group and Godrej group were established, addition under section 68 was unjustified. Share valuation is a commercial decision between parties. The company qualified as "public substantially interested" under section 2(18), making section 56(2)(viib) inapplicable. Reopening under section 147 was deemed impermissible change of opinion. Interest disallowance on inter-corporate deposits was also rejected. en-us Fri, 05 Apr 2024 00:00:00 +0530 Sat, 04 Jul 2026 12:32:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=751169 ITAT Mumbai dismissed revenue's appeal regarding additions under sections 68 and 56(2)(viib) for share premium receipts. The AO had questioned premium of Rs. 40 per share (face value Rs. 10) for a loss-making company without valuation basis. ITAT held that once identity, creditworthiness, and genuineness of transactions with Future group and Godrej group were established, addition under section 68 was unjustified. Share valuation is a commercial decision between parties. The company qualified as "public substantially interested" under section 2(18), making section 56(2)(viib) inapplicable. Reopening under section 147 was deemed impermissible change of opinion. Interest disallowance on inter-corporate deposits was also rejected. Case-Laws Income Tax Fri, 05 Apr 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=751169