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Showing contexts for: paripassu in B.S. And W. Whiteley Ltd. vs Income-Tax Officer on 10 May, 1995Matching Fragments
9. The authorities below did not treat this method of computation as proper. Precedents of the highest court ranging from Emerald & Co. Ltd v. CIT[1959] 36 ITR 257 (SC) down to Shekhawati General Traders Ltd v. ITO [1971] 82 ITR 788 (SC) were cited. The governing principle is clear and past all disputes. The method of valuation of shares, original and bonus, either for the purpose of capital gain or for the sake of making entry in accounts to show the closing or opening stock value, is the same. It is a case of original shares purchased for a price and bonus shares allotted by the company for which no cost had in fact been incurred. The Supreme Court has, on more than one occasion, ruled that the correct method to be applied in such cases is to take up the cost of the original shares and to spread it over to the original as well as bonus shares if the shares rank paripassu. This view taken in Emerald & Co. Ltd's case (supra) was approved in the case of CIT v. Dalmia lnvestment Co. Ltd [1964] 52ITR 567 (SC) and two subsequent decisions in the cases of CIT v. GoldMohore Investment Co. Ltd [1968] 68 ITR 213 (SC) and CIT v. Gold Mohore Investment Co. Ltd [1969] 74 ITR 62 (SC) and finally in the case of Shekhawati General Traders Ltd's case (supra).