https://www.taxtmi.com/caselaws?id=8654 For capital gains computation under section 48, "full value of consideration received" was construed as the actual consideration received by the transferor, not the market value of the shares. The section was therefore not treated as authorising substitution of market value for the price actually received. Section 52 was also held inapplicable to a share transfer to the transferor's sons where there was no finding that the transfer was effected to avoid or reduce tax liability; mere relationship between transferor and transferees was insufficient. The stated ratio is that actual consideration governs section 48, and section 52 requires a tax-avoidance purpose to operate. en-us Mon, 10 Apr 1972 00:00:00 +0530 Sat, 09 May 2009 19:14:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=8654 For capital gains computation under section 48, "full value of consideration received" was construed as the actual consideration received by the transferor, not the market value of the shares. The section was therefore not treated as authorising substitution of market value for the price actually received. Section 52 was also held inapplicable to a share transfer to the transferor's sons where there was no finding that the transfer was effected to avoid or reduce tax liability; mere relationship between transferor and transferees was insufficient. The stated ratio is that actual consideration governs section 48, and section 52 requires a tax-avoidance purpose to operate. Case-Laws Income Tax Mon, 10 Apr 1972 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=8654