https://www.taxtmi.com/caselaws?id=63433 For surtax computation under the Companies (Profits) Surtax Act, shares shown as investments in the balance sheet were excluded from deduction where the true arrangement showed that they were held only as trustee or conduit for another group. The deciding factor was beneficial ownership: the assessee had to acquire and hold the shares in its own name, vote as directed, renounce further rights issues, and transfer the benefit on payment. Mere balance-sheet classification did not change the real character of the holding. The impugned share values were therefore not deductible from paid-up capital and reserves, and capital had to be computed without reducing those values. en-us Thu, 30 May 1991 00:00:00 +0530 Mon, 31 Jan 2011 09:55:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=63433 For surtax computation under the Companies (Profits) Surtax Act, shares shown as investments in the balance sheet were excluded from deduction where the true arrangement showed that they were held only as trustee or conduit for another group. The deciding factor was beneficial ownership: the assessee had to acquire and hold the shares in its own name, vote as directed, renounce further rights issues, and transfer the benefit on payment. Mere balance-sheet classification did not change the real character of the holding. The impugned share values were therefore not deductible from paid-up capital and reserves, and capital had to be computed without reducing those values. Case-Laws Income Tax Thu, 30 May 1991 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=63433