https://www.taxtmi.com/caselaws?id=795996 Section 56(2)(viib) applies only where consideration is received for an actual issue of shares. Where holding-company share application money was subsequently converted into compulsorily convertible debentures and no shares were issued during the relevant year, the provision did not apply; the article notes that a holding-subsidiary premium transaction also does not confer the targeted benefit on an outside party. It further states that genuine salary, finance and other necessary business expenses remain deductible under section 37 even if no business income arises in the same year. The discussed additions and disallowance 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. Where holding-company share application money was subsequently converted into compulsorily convertible debentures and no shares were issued during the relevant year, the provision did not apply; the article notes that a holding-subsidiary premium transaction also does not confer the targeted benefit on an outside party. It further states that genuine salary, finance and other necessary business expenses remain deductible under section 37 even if no business income arises in the same year. The discussed additions and disallowance were deleted. Case-Laws Income Tax Wed, 15 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795996