Bench: Shri George Mathan & Shri Rakesh Mishra
56(2)(viia) of the Act applies only for the receipt of share and not for the allotment of share since only on allotment of shares, the shareholder receives the shares and not prior to the alloetmnet. The Ld. CIT(A) has relied upon the decision of Sudhir Memon HUF (supra) in which it has been held that a share