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    <title>2014 (5) TMI 705 - CALCUTTA HIGH COURT</title>
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    <description>Shares converted from investment to stock-in-trade had to be valued in accordance with the governing prudential norm, namely cost or break-up value, whichever was lower. The Court found that the assessee did not apply that basis at the date of conversion, and the negative break-up value reflected in the balance-sheet did not justify the higher valuation adopted. It also rejected parity with another company&#039;s shares because the two holdings were not shown to be of the same character, and dissimilar assets cannot be treated identically. The assessee&#039;s valuation was therefore unsustainable, and the addition based on the impugned share valuation was upheld.</description>
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      <title>2014 (5) TMI 705 - CALCUTTA HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=247778</link>
      <description>Shares converted from investment to stock-in-trade had to be valued in accordance with the governing prudential norm, namely cost or break-up value, whichever was lower. The Court found that the assessee did not apply that basis at the date of conversion, and the negative break-up value reflected in the balance-sheet did not justify the higher valuation adopted. It also rejected parity with another company&#039;s shares because the two holdings were not shown to be of the same character, and dissimilar assets cannot be treated identically. The assessee&#039;s valuation was therefore unsustainable, and the addition based on the impugned share valuation was upheld.</description>
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