https://www.taxtmi.com/caselaws?id=212072 The Tribunal's interpretation of section 47(v) was upheld: an Indian company cannot have fewer than two shareholders under the Companies Act, 1956, so "whole of the share capital" held by a holding company could not be read as requiring the shares to stand only in the holding company's name. A contrary Revenue construction was rejected because it would make section 47(v) ineffective in practice and was inconsistent with settled principles of interpretation. No substantial question of law was found to arise, and the appeal was dismissed. en-us Fri, 28 Aug 2009 00:00:00 +0530 Wed, 29 Jun 2016 14:29:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=212072 The Tribunal's interpretation of section 47(v) was upheld: an Indian company cannot have fewer than two shareholders under the Companies Act, 1956, so "whole of the share capital" held by a holding company could not be read as requiring the shares to stand only in the holding company's name. A contrary Revenue construction was rejected because it would make section 47(v) ineffective in practice and was inconsistent with settled principles of interpretation. No substantial question of law was found to arise, and the appeal was dismissed. Case-Laws Income Tax Fri, 28 Aug 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=212072