Conversion of share application money by allotting shares at subsequent date without change in shareholding pattern doesn’t attract section 56(2)(viia)

ATR Warehousing Private Limited Vs DCIT (ITAT Visakhapatnam) ITAT Visakhapatnam held that merely by converting the share application money by allotting shares at a subsequent date cannot attract the provisions of section 56(2)(viia) of the Income Tax Act 1961 as there is no change in the shareholding pattern subsequent to the allotment of shares by the subsidiary company. Facts- The assessee is deriving income from business and capital gains. The main source of business income was license fee collected from the tenants for the warehousing godowns at various places. The case of the assessee was...