Genuineness of sale price of shares - transfer of same share at...

Genuineness of sale price of shares - transfer of same share at different price - a much higher price in the hands of Empee Sugars & Chemicals Ltd., was undoubtedly to benefit to set off against capital gains against huge accumulated losses and at substantial lower price for benefit to the assessee by way of splitting up of the consideration for shares and non compete fee thereby being a device employed to evade tax - non compete fee is part of sales consideration