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    <title>2025 (2) TMI 1443 - ITAT DELHI</title>
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    <description>Extraordinary share premium credited at a premium over face value was challenged as income under section 56(2)(vii)(b); the tribunal held that questioning genuineness of the receipt attracts the unexplained receipts doctrine and assessment under that head, not the specified valuation provision, and deleted the addition because the statutory fair market value methods were not invoked. Separately, enhancement of income by the appellate authority on a new head not raised by the assessing officer was held unsustainable as it creates an altogether new income head; that enhancement was deleted accordingly.</description>
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      <description>Extraordinary share premium credited at a premium over face value was challenged as income under section 56(2)(vii)(b); the tribunal held that questioning genuineness of the receipt attracts the unexplained receipts doctrine and assessment under that head, not the specified valuation provision, and deleted the addition because the statutory fair market value methods were not invoked. Separately, enhancement of income by the appellate authority on a new head not raised by the assessing officer was held unsustainable as it creates an altogether new income head; that enhancement was deleted accordingly.</description>
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