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    <title>2025 (10) TMI 148 - ITAT DELHI</title>
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    <description>ITAT held additions under section 56(2)(viia) disallowing share allotments were illegal and set aside: the amendment targets transfers of unutilized/previously issued shares (e.g., rights transfers) and does not apply to fresh allotment/fresh issue of shares, so valuation-based additions on allotment were unsustainable. Separately, additions treating sundry debtors and related investments as unexplained/fictitious were also set aside where the AO&#039;s findings were internally inconsistent and could not support taxing alleged fictitious debtors in the prior year.</description>
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      <link>https://www.taxtmi.com/caselaws?id=779352</link>
      <description>ITAT held additions under section 56(2)(viia) disallowing share allotments were illegal and set aside: the amendment targets transfers of unutilized/previously issued shares (e.g., rights transfers) and does not apply to fresh allotment/fresh issue of shares, so valuation-based additions on allotment were unsustainable. Separately, additions treating sundry debtors and related investments as unexplained/fictitious were also set aside where the AO&#039;s findings were internally inconsistent and could not support taxing alleged fictitious debtors in the prior year.</description>
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