https://www.taxtmi.com/caselaws?id=795996 Section 56(2)(viib) applies only where consideration is received for an actual issue of shares. Share application money received from a holding company and later converted into compulsorily convertible debentures, without shares being issued during the relevant year, does not attract the provision. A premium arrangement between a holding company and its subsidiary also does not confer the targeted benefit on an outside party. Genuine salary costs, finance charges and other necessary business expenses remain deductible even where no business income arises in the same year. Consequently, the share-premium addition and disallowance of business expenditure were deleted. en-us Wed, 15 Jul 2026 00:00:00 +0530 Thu, 30 Jul 2026 08:52:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=795996 Section 56(2)(viib) applies only where consideration is received for an actual issue of shares. Share application money received from a holding company and later converted into compulsorily convertible debentures, without shares being issued during the relevant year, does not attract the provision. A premium arrangement between a holding company and its subsidiary also does not confer the targeted benefit on an outside party. Genuine salary costs, finance charges and other necessary business expenses remain deductible even where no business income arises in the same year. Consequently, the share-premium addition and disallowance of business expenditure were deleted. Case-Laws Income Tax Wed, 15 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795996