Income Tax Act Section 56(2)(viib): Preference shares not included in net asset value; additions under this section removed.

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....Addition u/s 56(2)(viib) - valuation under Rule 11UA (2) - Even if preferential shares and equity shares are considered to be falling within the purview of Section 56(2)(viib) of the Act, they stand on different footing . While the equity shareholders are the real owners of the company, the preference shareholders are not in fact, the owners of the company, they get preference over the equity shareholders on certain aspects. Hence the Net asset value of the company really represents the value of Equity shares and not "Preference shares" - Additions deleted - AT....