https://www.taxtmi.com/highlights?id=100576 Safe harbour under Rule 11UA(4) was treated as curative and retrospectively applicable: where the difference between issue price and the prescribed valuation did not exceed 10%, the issue price was deemed to be fair market value, so the section 56(2)(viib) addition on shares issued to the resident shareholder could not survive. Legal and professional charges for due diligence, business evaluation and advisory services connected with structuring and growth were held to be revenue expenditure, because no capital asset or enduring capital advantage was shown; the disallowance was deleted. en-us Mon, 08 Jun 2026 08:52:43 +0530 Mon, 08 Jun 2026 08:52:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=100576 Safe harbour under Rule 11UA(4) was treated as curative and retrospectively applicable: where the difference between issue price and the prescribed valuation did not exceed 10%, the issue price was deemed to be fair market value, so the section 56(2)(viib) addition on shares issued to the resident shareholder could not survive. Legal and professional charges for due diligence, business evaluation and advisory services connected with structuring and growth were held to be revenue expenditure, because no capital asset or enduring capital advantage was shown; the disallowance was deleted. Highlights Income Tax Mon, 08 Jun 2026 08:52:43 +0530 https://www.taxtmi.com/highlights?id=100576