https://www.taxtmi.com/highlights?id=102077 Section 56(2)(vii)(c) is discussed as applying where shares or securities are received from another person for inadequate consideration. The notes distinguish a fresh allotment from a transfer of existing property: newly issued shares arise from unissued share capital and do not pre-exist as property transferred by another person. On a strict construction of the deeming provision, the term "receives" is treated as requiring prior existence of the property. The discussion records that the provision was considered inapplicable to fresh share allotments, resulting in deletion of the related additions; the Revenue's challenge based on a sibling's earlier case was treated as academic. en-us Sat, 25 Jul 2026 08:54:57 +0530 Sat, 25 Jul 2026 08:54:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=102077 Section 56(2)(vii)(c) is discussed as applying where shares or securities are received from another person for inadequate consideration. The notes distinguish a fresh allotment from a transfer of existing property: newly issued shares arise from unissued share capital and do not pre-exist as property transferred by another person. On a strict construction of the deeming provision, the term "receives" is treated as requiring prior existence of the property. The discussion records that the provision was considered inapplicable to fresh share allotments, resulting in deletion of the related additions; the Revenue's challenge based on a sibling's earlier case was treated as academic. Highlights Income Tax Sat, 25 Jul 2026 08:54:57 +0530 https://www.taxtmi.com/highlights?id=102077