Share Premium Rounding Difference of Rs. 0.09 Per Share Not Taxable Under Section 56(2)(viib) for Rights Issue

ITAT ruled in favor of assessee regarding addition under s. 56(2)(viib) for alleged excess share premium. The disputed amount arose from a nominal rounding difference of Rs. 0.09 per share on allotment of 1 crore equity shares to existing shareholders in proportion to their shareholding ratio. The Tribunal found the CIT(A)'s order unsustainable as the share allotment maintained original shareholding patterns without substantive premium excess. The technical rounding difference did not constitute premium warranting addition under s. 56(2)(viib). Addition deleted based on assessee's submission demonstrating proportional allotment to existing shareholders with unchanged shareholding ratios. .....

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