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

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