sec 56(2)(x)

Sec. 56(2)(x) applies only in case of transfer of shares but share issue is not a transfer by company and hence shareholder in such case would also not be considered as transferee for the purpose of this section.

Remember, no capital gain provisions in hands of company at the time of issue of shares. Only COA arises in hands of shareholder and that too is nil in case of bonus shares.

but if company issue shares at lower than FMV..then this section will also apply..in that case it is also issue..so why in this case, this sec. is apply..

Please ignore my previous answer. New answer is as follows -
Issue of bonus shares is by definition capitalization of its profit by the issuing-company. There is neither any increase nor decrease in the wealth of the shareholder (or of the issuing company) on account of a bonus issue, and his percentage holding therein remains constant. In other words, there is no receipt of any property by the shareholder, and what stands received by him is the split shares out of his own holding. Thus section 56(2)(x) will not apply in case of bonus issue.