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- 20- appellant. According to the A.O, if during that period the treasury segment had not come into existence then the previous year comparative figures should have been shown at Nil. According to the A.O in A.Y.2008-09 SAIL was the subsidiary of the appellant. If Treasury Segment was created to look after the subsidiaries of the appellant then the investment in other subsidiaries such as Paras Overseas Holding Ltd. and Paras Inc. USA should have become the assets of the Treasury Segment. The A.O has also verified the trial balance of the treasury segment for A.Y.2009-10. According to the A.O the shares of Blue Information Ltd., Trent Limited and bonus shares of IDBI Ltd. were not reflected as assets of Treasury Segment. Further the shares of Shivalik Waste Management Ltd., were also not reflected as assets of the Treasury Segment in the trial balance for FY 2008-09. However, the shares of Blue Information Ltd., Trent Ltd., bonus shares of IDBI Ltd. and shares of Shivalik Waste Management Pvt. Ltd. were shown as assets before the Hon'ble High Court. The A.O has observed that the appellant had shown market value of shares to Trent Ltd. at Rs. 500 per share whereas on 7/10/2010 the market value was Rs. 1,045/-. Similarly, the market value of Blue Information Ltd. does not correspond with the market value as on 7/10/2010. As the bonus shares of the IDBI too were shown as assets of the Treasury Segment before the Hon'ble High Court and other shares of IDBI were not reflected in the trial balance of the appellant. On enquiry by the A.O, the appellant submitted that as these were the bonus shares, their value was 'Zero' and they did not appear in the trial balance. According to the A.O the trial balance is generated from the individual accounts and so long as the accounts of bonus shares is existed even though at the face value of 'zero' the shares should have been reflected in the trial balance. Similar issues of Blue Information Ltd. and Trent Ltd. should have been reflected in the trial balance and a separate head for 'diminishing of value of assets' should have appeared. Thus, according to the A.O this involves violation of sub-clause-3 of sub sec.(19AA) of sec.2. According to AO, the shares of Blue Information and Trent Ltd. have not been transferred at value as per the books. The A.O has further pointed out that the trial balance of Treasury Segment as on 31/3/2010 had reflected investments in mutual funds at Rs. 4,01,66,417/- and total investment of Rs. 36,24,90,963/-. The total investment figure matches with the total assets of the Treasury Segment as per the segment reporting in the audited balance sheet.