During previous year relevant to A.Y. 2014-15 the assessee had issued to 5,13,978 shares at Rs. 1,284.10 per share against the face value of Rs. 10 each and received a premium to the tune of Rs. 65.48 crores from its holding company. The details thereof had been submitted to the A.O. during the assessment proceedings which was completed u/s. 143(3) accepting NIL return filed without making adjustment in respect thereof. Subsequently, the CIT invoked provisions of section 263 and directed the A.O. to revise assessment for failuure of the A.O. to carry out necessary examination on justification of the share premium and the creditworthiness of the subscriber to whom shares had been allotted on such a huge premium. On appeal Tribunal held that the section 56(2)(viib) of the Act is wholly inapplicable for transactions between a holding company and its subsidiary company where no income can be said to accrue to the ultimate beneficiary, i. e., the holding company. Fair market value of shares issued was duly supported by the independent valuer’s report and there was no change in interest or control over money on issuance of shares. The A.O. was thus also satisfied with the parameters of section 68 of the Act towards such nature and source of such credits in the post-revision proceedings. In this backdrop, the extent of inquiry on the purported credibility of premium charged did not really matter as no prejudice could possibly result from the outcome of such inquiry. The chargeability of deemed income arising from transactions between holding and subsidiary or vice versa militates against the object of section 56(2)(viib) of the Act.  The revision by the Principal Commissioner in the context of the facts of the case was wholly unjustified and without meeting the jurisdictional requirement of section 263 of the Act. Editorial note :-Dy. CIT v. Ozone India Ltd. [2022 94 ITR (Trib) 609 (Ahd) applied. KBC India P. Ltd. v. ITO (I. T. A. No. 9710/Delhi/2019, dated November 2, 2022) approved.(AY. 2014-15)