https://www.taxtmi.com/caselaws?id=791204 Section 56(2)(viib) does not apply to conversion of CCDs into equity shares where no fresh consideration is received in the relevant previous year, because the provision is triggered only when a company receives consideration for issue of shares in excess of fair market value. The earlier receipt of funds on issue of CCDs meant the conversion did not attract the anti-abuse provision. For valuation, Rule 11U(b) and Rule 11UA require the balance sheet drawn up on the valuation date, or, if unavailable, the latest balance sheet preceding that date; on this basis, use of the audited balance sheet as on 31.03.2016 for NAV valuation was accepted. en-us Wed, 29 Apr 2026 00:00:00 +0530 Thu, 07 May 2026 07:08:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791204 Section 56(2)(viib) does not apply to conversion of CCDs into equity shares where no fresh consideration is received in the relevant previous year, because the provision is triggered only when a company receives consideration for issue of shares in excess of fair market value. The earlier receipt of funds on issue of CCDs meant the conversion did not attract the anti-abuse provision. For valuation, Rule 11U(b) and Rule 11UA require the balance sheet drawn up on the valuation date, or, if unavailable, the latest balance sheet preceding that date; on this basis, use of the audited balance sheet as on 31.03.2016 for NAV valuation was accepted. Case-Laws Income Tax Wed, 29 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791204