Section 56(2)(viib) was introduced to deter the use of unaccounted money done through subscription of shares of a closely held company, at a value that is higher than the FMV of the shares of such a company.
The issue with respect to the tax treatment of interest earned out of the share application money deposited with a bank due to a statutory requirement has been a matter of debate before the Courts.
The current dilemma faced by the government authorities is to come up with an efficient way of taxing cryptocurrencies, which in turn puts the crypto investor community in a jeopardy.