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The High Court of Bombay dismissed an application under section 26(3) of the Gift-tax Act, 1958, regarding the valuation of shares issued to partners of a firm taken over by a company. The court held that no deemed gift was involved and no gift-tax was chargeable, agreeing with the Income-tax Appellate Tribunal's decision that the shares encompassed all the assets of the company and profits were embedded in the transferred assets. The application was dismissed with no costs awarded.
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