https://www.taxtmi.com/caselaws?id=468804 Section 56(2)(viib) was held inapplicable where compulsorily convertible preference shares were issued by a subsidiary to its 100% holding company, because there was no change in control or shareholding and the subscription was by an existing shareholder. The deeming provision was treated as aimed at curbing unaccounted money and excessive premium in closely held companies, not ordinarily at capital infusions by a parent into a wholly owned subsidiary. The Tribunal also accepted that the assessee's valuation report could not be rejected merely on the Assessing Officer's approach, as the conversion structure had to be considered in determining fair market value. The share premium addition was deleted. en-us Fri, 07 Feb 2025 00:00:00 +0530 Wed, 20 May 2026 12:09:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468804 Section 56(2)(viib) was held inapplicable where compulsorily convertible preference shares were issued by a subsidiary to its 100% holding company, because there was no change in control or shareholding and the subscription was by an existing shareholder. The deeming provision was treated as aimed at curbing unaccounted money and excessive premium in closely held companies, not ordinarily at capital infusions by a parent into a wholly owned subsidiary. The Tribunal also accepted that the assessee's valuation report could not be rejected merely on the Assessing Officer's approach, as the conversion structure had to be considered in determining fair market value. The share premium addition was deleted. Case-Laws Income Tax Fri, 07 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468804