https://www.taxtmi.com/caselaws?id=795696 Section 56(2)(vii)(c)(ii) applies where property is received from another person for inadequate consideration. Fresh share allotment creates shares from unissued share capital and does not involve transfer of pre-existing property held by another person. As a deeming charging provision, it cannot be extended by implication to fresh issues not expressly covered by its language. Accordingly, the fair-market-value differential between the issue price and value of newly allotted shares is not taxable as deemed income under this provision, and an addition on that basis is unsustainable. en-us Wed, 15 Jul 2026 00:00:00 +0530 Sat, 25 Jul 2026 08:54:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=795696 Section 56(2)(vii)(c)(ii) applies where property is received from another person for inadequate consideration. Fresh share allotment creates shares from unissued share capital and does not involve transfer of pre-existing property held by another person. As a deeming charging provision, it cannot be extended by implication to fresh issues not expressly covered by its language. Accordingly, the fair-market-value differential between the issue price and value of newly allotted shares is not taxable as deemed income under this provision, and an addition on that basis is unsustainable. Case-Laws Income Tax Wed, 15 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795696