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TMI Blog2017 (4) TMI 302X X X X Extracts X X X X X X X X Extracts X X X X ..... s of M/s Annamalaiar Textiles (P) Ltd., before it was transferred to Group B. No payment was made to the shareholders belonging to Group B and, therefore, the question of there being any capital gains at the hands of the respondent herein does not arise. Needless to mention that the transaction of payment of ₹ 42.45 lakhs had been subjected under the Gift Tax Act and the Department cannot ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... P) Ltd., respondent herein is a holding company of M/s Annamalaiar Textiles (P) Ltd. Hundred per cent shares of M/s Annamalaiar Textiles (P) Ltd. were held by the respondent company. In the respondent company, there were two groups of shareholders; the majority shareholder called Group A was having 61.26 per cent shares whereas the minority shareholders called Group B were holding 38.74 per cent s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e both the companies are now 100 per cent owned by Group A or Group B, as the case may be, payment of ₹ 42.45 lakhs was to off set valuation of the shares of M/s Annamalaiar Textiles (P) Ltd. The Assessing Officer opined that the respondent herein-assessee was liable to pay tax for capital gains which was upheld in the appeal before the Commissioner of Income Tax (Appeals). However, the I ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ute that M/s Annamalaiar Textiles (P) Ltd. did not pay any amount to the shareholders who ultimately got the shares transferred in their names. The respondent was holding 100 per cent shares of M/s Annamalaiar Textiles (P) Ltd., before it was transferred to Group B. No payment was made to the shareholders belonging to Group B and, therefore, the question of there being any capital gains at the han ..... X X X X Extracts X X X X X X X X Extracts X X X X
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