AO Cannot Apply Post-2018 “Look-Through” Valuation Retrospectively – ITAT Deletes Massive Section 56 Additions

ACIT Vs Kanchan Markhedkar (ITAT Mumbai) The Mumbai ITAT upheld deletion of additions exceeding ₹10.57 crore made under section 56(2)(vii)(c), holding that for AYs 2015-16 and 2016-17, the Assessing Officer could not adopt a “look-through” approach by valuing underlying subsidiary companies instead of the shares actually purchased by the assessee. The Revenue alleged that the assessee and family members had acquired control of companies having huge share premium and assets through intermediary holding companies at nominal value, thereby indirectly acquiring underlying shares far below fa...