In the result, ground V of the assessee is allowed
Bench: Shri Anikesh Banerjee & Shri Gagan Goyal
money by such issuance of shares. The object of deeming an unjustified premium charged o, issue of share as taxable income under Section 56(2)(viih) is wholly inapplicable for transaction between holding and its subsidiary company where no income can be said to accrue to the u/fimati beneficiary
