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Ground of appeal raised by the assessee are that on the facts and in the circumstances of the case and in law, the learned CIT(A) has erred in confirming the action of the AO in making addition under section 56(2)(viib) of the Act in relation to issuance of shares by the Appellant to its holding company, Vodafone Idea Limited (earlier known as Vodafone India Limited which stands merged with Idea Cellular Limited and consequently known as Vodafone Idea Limited) at a premium.

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Sec. 56 of the Income-tax Act, 1961 - Income from other sources - For valuation of an intangible asset, only the future projections along can be adopted and such valuation cannot be reviewed with actual after 3 or 4 years down the line. Appeal of the assessee allowed. - VODAFONE M-PESA LTD. V/s DY. CIT - [2020] 181 ITD 242 (ITAT-MUMBAI)

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