ACIT v. Dewanchand Ramsaran Industries (P) LTD. (2025) 236 TTJ 205 / 173 taxmann.com 743 (Mum)(Trib)

S. 28(iv): Business income-Value of any benefit or perquisites-Converted into money or not-Share application money-Shares issued after some years-Capital receipt]-Not taxable as business income.[S.4]

Held that share application money from its existing shareholders in earlier years and ultimately issued and allotted the shares to the respective investors in a later year, it has to be accepted that the receipt of share application money is a capital receipt in the hands of the assessee and, therefore, the same is not liable to be taxed under the provisions of s. 28(iv).(AY. 2017-18)

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