https://www.taxtmi.com/caselaws?id=786544 Section 56(2)(viia) applies to receipt of shares of a closely held company even when those shares arise by fresh allotment; where consideration paid is less than the aggregate fair market value, the difference is taxable as income. The statutory language treats 'receives' broadly and does not require pre existing property in the allotter; administrative guidance (Circular No. 3/2019) and tribunal reasoning support application to allotments at undervalue. Valuation under Rule 11UA was applied to determine fair market value, and additions based on fund rotation and accommodation entry findings were sustained, resulting in taxability of the differential. en-us Tue, 10 Feb 2026 00:00:00 +0530 Sat, 14 Feb 2026 08:29:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=786544 Section 56(2)(viia) applies to receipt of shares of a closely held company even when those shares arise by fresh allotment; where consideration paid is less than the aggregate fair market value, the difference is taxable as income. The statutory language treats 'receives' broadly and does not require pre existing property in the allotter; administrative guidance (Circular No. 3/2019) and tribunal reasoning support application to allotments at undervalue. Valuation under Rule 11UA was applied to determine fair market value, and additions based on fund rotation and accommodation entry findings were sustained, resulting in taxability of the differential. Case-Laws Income Tax Tue, 10 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=786544