1986 (12) TMI 72

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..... 's appeal in respect of addition of Rs. 6 lakhs made in the assessment framed on 19-10-1982 under section 16(3) of the Wealth-tax Act, 1957 ('the Act') in respect of the assessment year 1978-79, for which the valuation date was 31-3-1978. The question is whether the assessee was rightly denied exemption under section 5(1)(xxiii) of the Act, in relation to Rs. 6 lakhs, which was remitted in favour .....

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..... in clause (xx) or clause (xxa) in any Indian company where the assessee is an individual or a Hindu undivided family ;" 4. From a plain reading of the above, it is clear that the mandate of the provision is that exemption would be available in respect of shares. The assessee's case has been that share application money should be equated with the shares applied for and allotted even after the va .....

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..... (Appellate Tribunal) Rules, 1963. 6. According to us, share application money by no stretch of imagination can be considered as the same thing as shares. There is no indication or any mandate even by implication that a different treatment should be meted out, when money is remitted from abroad for allotment of shares because in all such cases there is bound to be spacing between the intention t .....

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