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    <description>Allotment of fresh shares to new shareholders at face value, where the market value is substantially higher, may fall within the Gift Tax Act&#039;s deeming provision because the statute treats transfers for inadequate consideration as gifts and defines transfer of property broadly. The text distinguishes this from a rights issue or bonus issue, noting that the shares were issued to new shareholders and not created in the context addressed by Khoday Distilleries. On that basis, the earlier ratio was considered inapplicable to the stated facts, and the transaction was treated as a deemed gift under the statutory scheme.</description>
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