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ITAT examined whether income or deemed income arose in the assessee's hands from an alleged transfer of immovable property/shares. On facts, the Tribunal found no transfer of title or interest by the assessee to any third party; there was only a reduction in percentage shareholding, not a conveyance of property rights. Relying on the Delhi HC ruling in a similar transaction, ITAT held that in absence of transfer of any part of interest or title in the immovable property, no income or deemed income could be attributed to the assessee. Additions made in the assessee's hands were therefore unsustainable and stood deleted.
ITAT examined whether income or deemed income arose in the assessee's hands from an alleged transfer of immovable property/shares. On facts, the Tribunal found no transfer of title or interest by the assessee to any third party; there was only a reduction in percentage shareholding, not a conveyance of property rights. Relying on the Delhi HC ruling in a similar transaction, ITAT held that in absence of transfer of any part of interest or title in the immovable property, no income or deemed income could be attributed to the assessee. Additions made in the assessee's hands were therefore unsustainable and stood deleted.
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