https://www.taxtmi.com/caselaws?id=782436 ITAT Mumbai held that the assessee, being a DPIIT-registered start-up, is entitled to immunity from applicability of section 56(2)(viib) in view of the CBDT circular and DPIIT notification. However, the Tribunal clarified that such immunity does not extend to proceedings under section 68, and therefore allowed the revenue's ground on this legal issue. On merits of the addition under section 68, ITAT upheld the CIT(A)'s deletion of the share premium addition, noting that the assessee had discharged its onus by proving identity, creditworthiness and genuineness of investors, and the AO was given adequate opportunity in remand. The revenue's appeal was thus partly allowed. en-us Wed, 26 Nov 2025 00:00:00 +0530 Sat, 29 Nov 2025 07:57:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=782436 ITAT Mumbai held that the assessee, being a DPIIT-registered start-up, is entitled to immunity from applicability of section 56(2)(viib) in view of the CBDT circular and DPIIT notification. However, the Tribunal clarified that such immunity does not extend to proceedings under section 68, and therefore allowed the revenue's ground on this legal issue. On merits of the addition under section 68, ITAT upheld the CIT(A)'s deletion of the share premium addition, noting that the assessee had discharged its onus by proving identity, creditworthiness and genuineness of investors, and the AO was given adequate opportunity in remand. The revenue's appeal was thus partly allowed. Case-Laws Income Tax Wed, 26 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=782436