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of Nature of receipt - money received by the assessee for issue of shares but the shares could not be issued due to contravention of FEMA guidelines - AO treated the same as gift by the assessee company or in terms of Section 28(iv) r.w.s. 2(24)(ix) - Alertpay Quebec was not the Holding Company of assessee company. Hence we hold that the observation made by the ld AO in this regard is factually incorrect. - AT
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