https://www.taxtmi.com/caselaws?id=766646 The Appellate Tribunal dismissed the Revenue's appeal, upholding the CIT(A)'s decision to delete the Rs. 16,46,40,000 addition made by the Assessing Officer under section 56(2)(viib) of the Income Tax Act, 1961. The Tribunal agreed with the CIT(A) that the deeming fiction of section 56(2)(viib) does not apply to transactions between a holding company and its wholly owned subsidiary where no benefit accrues to outsiders. The Tribunal's decision was supported by various precedents, and the order was pronounced on 27th February 2025. 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=766646 The Appellate Tribunal dismissed the Revenue's appeal, upholding the CIT(A)'s decision to delete the Rs. 16,46,40,000 addition made by the Assessing Officer under section 56(2)(viib) of the Income Tax Act, 1961. The Tribunal agreed with the CIT(A) that the deeming fiction of section 56(2)(viib) does not apply to transactions between a holding company and its wholly owned subsidiary where no benefit accrues to outsiders. The Tribunal's decision was supported by various precedents, and the order was pronounced on 27th February 2025. Case-Laws Income Tax Thu, 27 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=766646