Section 56(2)(viib) could not be applied in the case of a transaction between holding company and wholly owned subsidiary in the absence of any benefit occurring to any outsider.”
The Delhi bench of the Income Tax Appellate Tribunal (ITAT) has deleted the addition made, as the holding-subsidiary transaction does not attract taxation under Section 56(2)(viib) of the Income Tax Act, 1961, in the absence of any benefit occurring to any outsider. The Revenue has challenged the additions of Rs.4, 09, 11,014/- made by the…
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