https://www.taxtmi.com/caselaws?id=12541 Section 52 could not be invoked to substitute a higher consideration for capital gains on the transfer of shares because the onus lies on the Revenue to prove understatement of consideration and receipt of any amount over and above the declared value, as clarified by SC in K.P. Varghese. Since the appellate authority and Tribunal concurrently found no material showing that the declared sale consideration was understated or that the assessee received any additional consideration directly or indirectly, section 52 was held inapplicable; consequently, the Revenue's appeal was dismissed and no interference was warranted. en-us Fri, 03 May 2002 00:00:00 +0530 Wed, 31 Dec 2025 14:39:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=12541 Section 52 could not be invoked to substitute a higher consideration for capital gains on the transfer of shares because the onus lies on the Revenue to prove understatement of consideration and receipt of any amount over and above the declared value, as clarified by SC in K.P. Varghese. Since the appellate authority and Tribunal concurrently found no material showing that the declared sale consideration was understated or that the assessee received any additional consideration directly or indirectly, section 52 was held inapplicable; consequently, the Revenue's appeal was dismissed and no interference was warranted. Case-Laws Income Tax Fri, 03 May 2002 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=12541