https://www.taxtmi.com/caselaws?id=122193 Transfer of shares is completed only when the contractual conditions are fulfilled, approval is obtained, and the transfer deeds and share certificates are delivered; an agreement to sell does not by itself complete the sale. Applying that principle, the shares were treated as transferred on the later effective date, when the holding company relationship existed, so the transaction fell within section 47(v) and capital gains were not taxable. The contention that the arrangement was a colourable device was rejected because the sequence of events was regarded as genuine and legally effective, and the CBDT circular could not override the statutory position. en-us Mon, 31 May 2010 00:00:00 +0530 Thu, 09 Aug 2012 13:01:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=122193 Transfer of shares is completed only when the contractual conditions are fulfilled, approval is obtained, and the transfer deeds and share certificates are delivered; an agreement to sell does not by itself complete the sale. Applying that principle, the shares were treated as transferred on the later effective date, when the holding company relationship existed, so the transaction fell within section 47(v) and capital gains were not taxable. The contention that the arrangement was a colourable device was rejected because the sequence of events was regarded as genuine and legally effective, and the CBDT circular could not override the statutory position. Case-Laws Income Tax Mon, 31 May 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=122193