Income Tax Act Section 56(2)(viib) Case: Share Valuation and Residency Status of Non-Resident Investor u/r 11U.

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....Addition u/s 56(2) (viib) - shares issued to NRI mainly to encourage Foreign Investments - valuation of shares in compliance to Rule 11U - there is no finding of AO or CIT(A) on this aspect as to whether the said person from whom the amount in question was received by the assessee company was a resident in India or not in the present year.....