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    <title>2016 (4) TMI 348 - ITAT AHMEDABAD</title>
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    <description>A transfer of shares under an enforceable family arrangement made to equalise holdings and consolidate family assets was not treated as a gift, because such an arrangement carried consideration and obligations rather than a voluntary transfer without consideration. The resultant surplus on sale of those shares was therefore regarded as profit and was required to be reflected in the profit and loss account for computation of book profit under section 115JB. Following its earlier view in the assessee&#039;s own case, the Tribunal upheld the adjustment and accepted the Revenue&#039;s position on both issues.</description>
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      <description>A transfer of shares under an enforceable family arrangement made to equalise holdings and consolidate family assets was not treated as a gift, because such an arrangement carried consideration and obligations rather than a voluntary transfer without consideration. The resultant surplus on sale of those shares was therefore regarded as profit and was required to be reflected in the profit and loss account for computation of book profit under section 115JB. Following its earlier view in the assessee&#039;s own case, the Tribunal upheld the adjustment and accepted the Revenue&#039;s position on both issues.</description>
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