Capital surplus is taxable or not

In the context of Income Tax Act 1961 

if closely held company (pvt co) issue share where 

 issue price of share > fair market value of share then the difference shall be taxable under head IFOS in the hands of COMPANY 

The amount is taxable in sec 56 of income tax act but the valuation of share would be done by the merchant banker and not on the bases of book value.