provision is applicable to
a transaction of issuance of shares to resident shareholders. However, the
shares were issued to M/s Otter ... applicable to aforesaid issue of shares by the assessee to non-
resident, the invocation of provision of section 56(2) (viib
assessment under sec. 143(3)
accepting the sale consideration per share was already framed, invocation of provisions
under sec. 153C ... assessment under sec. 143(3)
accepting the sale consideration per share was already framed, invocation of provisions
under sec. 153C
designated authority for working out the value
of shares, was extraneous and superfluous and merited to be
ignored. The Ld. Counsel asserted that the valuation ... 2678/Del/2019
valuation of shares over the fair market value. Accordingly the
invocation of the provisions of Sec.56(2)(viib
fiction of section 50CA in the present
proceedings, as the unquoted equity shares of UEM, were transferred in FY
2015-16 prior ... that the AO's invocation of section 50 of the Act to consider the 'sale of
shares' as 'sale of asset
supplied the information for valuation of its own
shares and independent valuer has valued the shares by adopting the above
information and the valuer ... supra) also the principle
issue was concerning valuation of shares issued to sister concern and invocation of
Section 56(2)(viib) . The ld. Counsel further
transactions of allotment of shares by
write issue by JAM India Pvt. Ltd. and therefore, invocation of
provisions to make the impugned addition ... Appeals)
while upholding and sustaining the addition, has failed to
appreciate that shares had been purchased by the assessee
on the basis of book value
assessment under sec. 143(3) accepting the sale consideration per share was
already framed, invocation of provisions under sec. 153C ... assessee on account of undisclosed capital gain on sale of
shares of Bahal Sons Properties Pvt. Ltd., thus do not survive in view
gain. The assessee was holding the shares admittedly as
investment and, therefore, capital gain earned on sale of
shares was in the nature of long ... account of three
transactions of acquisition of shares and one transaction of sale of
shares.
11.1 It is settled law that that frequency and magnitude
partners were holding
more than 10 per cent shares - Whether
addition was justified - Held, yes [In favour of
revenue]
2.[2011] 14 taxmann ... found to be the beneficial owner of
the shares - YES: SC
Whether, for the invocation of provisions of
Sec 2(22)(e), the requirement
mium of Rs. 90/- per share has
been contributed by the share holders o wing to various facts
that the company had purchased the land ... disputed the identity, genuineness and
creditworthiness of the share holde rs. Hence , the invocation of
the provisions of Section 68 of the Income
