https://www.taxtmi.com/caselaws?id=70357 For gift-tax valuation of unquoted shares in a private company, the break-up method was preferred over capitalising yield where the company's assets could be ascertained, and the capitalised-yield approach was rejected. A discount was also justified for the restriction on transferability, since such limits depress market value and a reasonable deduction may be allowed even without direct application of the wealth-tax rules. Further, the transferor's continuing one-third coparcenary interest in the transferee HUF had to be taken into account, because that retained proprietary interest reduced the effective value passing under the transfer. The transfer was therefore supported by adequate consideration only to the extent of these deductions, and the balance alone was treated as taxable gift. en-us Fri, 14 Oct 1983 00:00:00 +0530 Fri, 15 Apr 2011 17:25:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=70357 For gift-tax valuation of unquoted shares in a private company, the break-up method was preferred over capitalising yield where the company's assets could be ascertained, and the capitalised-yield approach was rejected. A discount was also justified for the restriction on transferability, since such limits depress market value and a reasonable deduction may be allowed even without direct application of the wealth-tax rules. Further, the transferor's continuing one-third coparcenary interest in the transferee HUF had to be taken into account, because that retained proprietary interest reduced the effective value passing under the transfer. The transfer was therefore supported by adequate consideration only to the extent of these deductions, and the balance alone was treated as taxable gift. Case-Laws Income Tax Fri, 14 Oct 1983 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=70357