https://www.taxtmi.com/caselaws?id=111503 Remission of stamp duty under the exemption notification was available only where, in a transfer between a parent and subsidiary company, one entity was the beneficial owner of not less than 90% of the issued share capital of the other. The notification, being part of a fiscal scheme, was construed strictly, and its plain wording was applied as registered documents showed the transferor did not satisfy the 90% issued share capital requirement. The argument that "issued share capital" could be read as "subscribed share capital" was rejected because the notification used a specific expression that had to be given its ordinary meaning. The remission was therefore unavailable and the stamp duty demand was upheld. en-us Fri, 09 Feb 2007 00:00:00 +0530 Mon, 23 Apr 2012 17:28:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=111503 Remission of stamp duty under the exemption notification was available only where, in a transfer between a parent and subsidiary company, one entity was the beneficial owner of not less than 90% of the issued share capital of the other. The notification, being part of a fiscal scheme, was construed strictly, and its plain wording was applied as registered documents showed the transferor did not satisfy the 90% issued share capital requirement. The argument that "issued share capital" could be read as "subscribed share capital" was rejected because the notification used a specific expression that had to be given its ordinary meaning. The remission was therefore unavailable and the stamp duty demand was upheld. Case-Laws Companies Law Fri, 09 Feb 2007 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=111503