https://www.taxtmi.com/caselaws?id=66753 Allotment of fresh shares by a company to its shareholders was analysed as not constituting a transfer of the company's property. A company remains a juristic person distinct from its shareholders, and a shareholder on allotment acquires only the rights attached to the shares, not any proprietary interest in the company's assets. Because deemed gift taxation under section 4(1)(a) of the Gift-tax Act applies only where property is transferred for inadequate consideration, the absence of any transfer meant the charge could not arise. On that reasoning, the addition was stated to be unsustainable and no deemed gift arose. en-us Wed, 21 Apr 1982 00:00:00 +0530 Mon, 07 Mar 2011 10:57:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=66753 Allotment of fresh shares by a company to its shareholders was analysed as not constituting a transfer of the company's property. A company remains a juristic person distinct from its shareholders, and a shareholder on allotment acquires only the rights attached to the shares, not any proprietary interest in the company's assets. Because deemed gift taxation under section 4(1)(a) of the Gift-tax Act applies only where property is transferred for inadequate consideration, the absence of any transfer meant the charge could not arise. On that reasoning, the addition was stated to be unsustainable and no deemed gift arose. Case-Laws Income Tax Wed, 21 Apr 1982 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=66753