Bringing the non-resident investors within the ambit of section 56(2)(viib) to eliminate the possibility of tax avoidance

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....viib) of the Act, inter alia, provides that where a company, not being a company in which the public are substantially interested, receives, in any previous year, from any person being a resident, any consideration for issue of shares that exceeds the face value of such shares, the aggregate consideration received for such shares as exceeds the fair market value of the shares shall be chargeable t....