https://www.taxtmi.com/caselaws?id=766659 ITAT Delhi ruled that CIT's revision u/s 263 was invalid regarding valuation of CCPS issued to holding company. Tribunal held that s. 56(2)(viib) provisions don't apply to transactions between subsidiary and 100% holding company, as share issuance to holding company doesn't involve circulation of unaccounted money. Relying on precedents including FIS Payment Solutions and BLP Vayu, ITAT found twin conditions of s. 263 weren't satisfied simultaneously. Assessment order wasn't erroneous per se, making revisional jurisdiction unavailable. Assessee's appeal was allowed. en-us Thu, 27 Feb 2025 00:00:00 +0530 Sat, 01 Mar 2025 08:25:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=766659 ITAT Delhi ruled that CIT's revision u/s 263 was invalid regarding valuation of CCPS issued to holding company. Tribunal held that s. 56(2)(viib) provisions don't apply to transactions between subsidiary and 100% holding company, as share issuance to holding company doesn't involve circulation of unaccounted money. Relying on precedents including FIS Payment Solutions and BLP Vayu, ITAT found twin conditions of s. 263 weren't satisfied simultaneously. Assessment order wasn't erroneous per se, making revisional jurisdiction unavailable. Assessee's appeal was allowed. Case-Laws Income Tax Thu, 27 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=766659