https://www.taxtmi.com/caselaws?id=797232 Section 56(2)(viib) does not support an addition for excess share premium where the issue price falls within the 10% safe-harbour variation from the fair market value determined under Rule 11UA. Rule 11UA(4), read with Notification No. 81/2023, treats an issue price within that tolerance as fair market value. Since the variation between the issue price and Rule 11UA valuation was 3.98%, the issue price was deemed to be fair market value and the addition was unsustainable. en-us Thu, 13 Aug 2026 00:00:00 +0530 Wed, 19 Aug 2026 08:20:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797232 Section 56(2)(viib) does not support an addition for excess share premium where the issue price falls within the 10% safe-harbour variation from the fair market value determined under Rule 11UA. Rule 11UA(4), read with Notification No. 81/2023, treats an issue price within that tolerance as fair market value. Since the variation between the issue price and Rule 11UA valuation was 3.98%, the issue price was deemed to be fair market value and the addition was unsustainable. Case-Laws Income Tax Thu, 13 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797232