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The Tribunal upheld that the anti abuse provision concerning receipt of shares applies to allotment as well as receipt, rejecting the argument that shares must pre exist to attract tax. Applying a wide interpretation of 'receipt', the Tribunal followed precedent holding that shares come into existence on allotment and acquisition by allotment constitutes receipt for tax purposes; consequently the appellant's challenge to the addition under the anti abuse provision was dismissed and the assessment upheld.
The Tribunal upheld that the anti abuse provision concerning receipt of shares applies to allotment as well as receipt, rejecting the argument that shares must pre exist to attract tax. Applying a wide interpretation of 'receipt', the Tribunal followed precedent holding that shares come into existence on allotment and acquisition by allotment constitutes receipt for tax purposes; consequently the appellant's challenge to the addition under the anti abuse provision was dismissed and the assessment upheld.
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