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    <title>Valuation of share premium and applicability to non-resident subscribers: rectification extinguishes addition and addition deleted on merits</title>
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    <description>Rectification of an assessment order extinguished the earlier addition made for share premium, merging the rectified order with the original assessment and preventing appellate re-adjudication; consequently the deletion effected by the assessing officer under rectification stands effective. Separately, where share subscribers were non-residents and no evidence supported domestic place of effective management, the valuation provision for share premium did not apply to shares issued to non-resident subscribers, so the addition was unsustainable on merits and deleted.</description>
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    <pubDate>Fri, 23 Jan 2026 09:11:01 +0530</pubDate>
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      <description>Rectification of an assessment order extinguished the earlier addition made for share premium, merging the rectified order with the original assessment and preventing appellate re-adjudication; consequently the deletion effected by the assessing officer under rectification stands effective. Separately, where share subscribers were non-residents and no evidence supported domestic place of effective management, the valuation provision for share premium did not apply to shares issued to non-resident subscribers, so the addition was unsustainable on merits and deleted.</description>
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