Section 56(2)(viia) Share Valuation Rules Not Applicable to Foreign Companies; Rule 11U Amendments Are Prospective Only.

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....Addition u/s 56(2)(viia) - valuation of purchasing the shares of foreign company from its directors - Provisions of section 56(2)(viia) cannot apply to a foreign company as the relevant Rule 11U which defines ‘balance sheet’ was not applicable to a foreign company. - The amendment in the rule is only prospective in nature and cannot apply to the year under appeal.....