Raw Pressery (P) Ltd. (2022) 220 TTJ 26 / 143 taxmann.com 158 (Mum)(Trib)

S. 56 : Income from other sources-Shares issued-Non-Resident-Provision is not applicable. [S. 2(24)(xvi), 56(2)(viib)]

Held that where shares were issued  to non-residents, section 56(2)(viib), read with section 2(24)(xvi) could not have been made applicable to shares issued to non-residents mainly to encourage foreign investments. Addition was deleted. (AY.  2018-19)