No section 68 addition for share allotment on premium by book adjustment

ACIT Vs Semall Impex Private Limited (ITAT Kolkata)

We find that undisputedly the assessee company has issued shares of Rs. 4,00,000/- of face value of Rs. 10/- each at a premium of Rs. 100/- to the holding company Deltmal Safety Shoes Pvt. Ltd. We also note that the assessee used to make purchases from the holding company and the assessee owed huge money to the holding company for the said supplies. This is also undisputed that there was no money transactionsbetween the assessee and holding company and the shares were issued amounting to Rs. 4,40,00,00

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