Deemed gift — Allotment of shares by assessee to three individuals who were interested in the affairs of the company, and the amount outstanding to the credit of account which were adjusted against the face value of the share allotted to them, amounts to transfer of property under s 2(xxiv)(d) — as held by ChenTrib in CIT v Centwin Textile Mills Ltd — In favour of: The revenue.
The shares were given at a much lesser value only to favour the buyer. It is not the case of the assessee that the shares were sold at the market value available at that time and that the buyer/shareholders have paid the market value of the shares allotted to them and the purchasers have no interest over the company.
Decided on: 8 September 2011.
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