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Tax alert: On issue of shares by WOS, matter remanded to consider favourable ITAT rulings on section 56(2)(viib) applicability

 

23 September 2024

The Delhi High Court, in relation to applicability of section 56(2)(viib) of the Income-tax Act, 1961 on issuance of shares by a wholly‑owned subsidiary (WOS) to its holding company, has remanded the matter back to the Dispute Resolution Panel (DRP) for considering the matter afresh after considering earlier favorable rulings of the Delhi Bench of the Income‑tax Appellate Tribunal (ITAT).  

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