2019 (6) TMI 1675

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....ged in the business of trading in investment and giving loans and advances. The return of income for the year under consideration was filed by it on 19.08.2013 declaring a total income of Rs. 1,38,610/-. As noted by the AO during the course of assessment proceedings, unquoted equity shares were sold by the assessee at Rs. 100 per share as against its Fare Market Value of Rs. 98/-. Since 1,84,000 such shares were sold by the assessee, the amount of Rs. 3,68,000/- (1,84,000 shares X Rs. 2/-) was added by him to the total income of the assessee u/s 56(2)(viib) in the assessment completed u/s 143(3) of the Act vide an order dated 21.03.2016. 3. Against the order passed by the AO u/s 143(3), an appeal was filed by the assessee before the Ld. ....

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.... appeal, statement of facts and submissions of the authorised representative of the appellate company as well as the assessment order framed in the light of materials available on record before the Assessing Officer during the assessment proceedings. The AO has mentioned in the order that the book value of the company comes to Rs. 14.92 and shares were issued at the rate of Rs. 15/- and accordingly the addition was made on difference amount. The AR has submitted that the fraction of Rs. 0.08 per share is only to round off of 8 paisa is negligible and it was done for rounding off the amount. Keeping in view of the facts as mentioned above, the AO is directed to delete the addition. The ground of appeal is allowed. I have gone throug....