https://www.taxtmi.com/caselaws?id=755173 ITAT Mumbai upheld the CIT(A)'s deletions: addition under s.56(2)(viib) was disallowed because the AO failed to rebut a DCF-based valuation and had not applied prescribed methods, and the shares were subscribed by an external corporate investor of unquestioned genuineness. The pro rata disallowance under s.36(1)(iii) was deleted as zero-coupon debentures were treated as sale consideration for transfer of assets/liabilities to a transferee company, not as an investment. Disallowance relating to an interest-free deposit was also deleted since available own funds supported the advance. Revenue's appeal dismissed; assessee's grounds allowed. en-us Tue, 19 Dec 2023 00:00:00 +0530 Fri, 22 Aug 2025 12:35:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=755173 ITAT Mumbai upheld the CIT(A)'s deletions: addition under s.56(2)(viib) was disallowed because the AO failed to rebut a DCF-based valuation and had not applied prescribed methods, and the shares were subscribed by an external corporate investor of unquestioned genuineness. The pro rata disallowance under s.36(1)(iii) was deleted as zero-coupon debentures were treated as sale consideration for transfer of assets/liabilities to a transferee company, not as an investment. Disallowance relating to an interest-free deposit was also deleted since available own funds supported the advance. Revenue's appeal dismissed; assessee's grounds allowed. Case-Laws Income Tax Tue, 19 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=755173