Reopening quashed due to change in opinion as final order confirmed addition u/s 68 instead of alleged section 56

Ideacount Education Pvt. Ltd. Vs ACIT (ITAT Mumbai) Facts- The matter of the assessee was re-opened on the ground that the assessee had issued 10 Lakhs shares at a price of INR 148 per share, however, the book value per share was INR 118.63 as per AO. Hence, the sum of INR 9,86,87,002/- being excess the premium charged as revenue income under section 56 of the Act. Conclusion- In present case, no addition was made under section 56. However, AO has made addition of share capital under section 68 of the Act. In our view no addition under section 68 of the Act on account of share capital could ha...