https://www.taxtmi.com/caselaws?id=5596 A forced transfer of shares, made without tax-avoidance motive, did not attract the proviso to section 12B(2), so market value substitution was not required. A loss on a standing guarantee given for a subsidiary became deductible only when liquidation ended and the unrecovered balance was finally ascertained; earlier liquidation recoveries were not taxable as separate income in prior years. Payments to directors of subsidiary companies were not deductible because they lacked a direct nexus with the assessee's own business and were made only to relieve the subsidiaries' remuneration restriction. The appeals thus failed on all issues, with the first two points favouring the assessee and the third against it. en-us Fri, 25 Apr 1997 00:00:00 +0530 Tue, 21 Jul 2026 15:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=5596 A forced transfer of shares, made without tax-avoidance motive, did not attract the proviso to section 12B(2), so market value substitution was not required. A loss on a standing guarantee given for a subsidiary became deductible only when liquidation ended and the unrecovered balance was finally ascertained; earlier liquidation recoveries were not taxable as separate income in prior years. Payments to directors of subsidiary companies were not deductible because they lacked a direct nexus with the assessee's own business and were made only to relieve the subsidiaries' remuneration restriction. The appeals thus failed on all issues, with the first two points favouring the assessee and the third against it. Case-Laws Income Tax Fri, 25 Apr 1997 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=5596