Section 56(2)(viib) not applicable to transaction between holding & wholly owned subsidiary

BLP Vayu (Project-1) Pvt. Ltd Vs PCIT (ITAT Delhi) The assessee company issued 513978 shares @ Rs 1284.10 per share to its 100% Holding Company in tune with the valuation report following DCF method towards calculation of fair market value of shares as per Rule 11UA(2)(b) of the Income Tax Rules for which share application money was received in AY 2013-2014. Assessment for AY 2013-2014 and AY 2014-15 were completed u/s 143(3) of the Act. LD PCIT set aside the order for AY 2014-2015 u/s 263 of the Act for failure of the ld AO to examine the genuineness of the transactions, creditworthiness of t...